Data / Federal rules / 2024-15232
Guidance Under Section 367(b) Related to Certain Triangular Reorganizations and Inbound Nonrecognition Transactions
The Internal Revenue Service published this final rule in the Federal Register on July 18, 2024. It took effect on July 17, 2024.
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What the agency says
This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to such reorganizations; and the treatment of certain subsequent inbound nonrecognition transactions following such reorganizations and certain other transactions. The final regulations affect corporations engaged in certain triangular reorganizations involving one or more foreign corporations, certain shareholders of foreign corporations acquired in such reorganizations, and foreign corporations that participate in certain inbound nonrecognition transactions.
Key facts
- Document number
- 2024-15232
- Type
- Final rule
- Action
- Final regulations
- Agency
- Treasury Department; Internal Revenue Service
- Published
- July 18, 2024
- Takes effect
- July 17, 2024
- Dates
- Effective date: These regulations are effective on July 17, 2024.
- Docket
- TD 10004
- Regulation ID (RIN)
- 1545-BM19
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 12
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