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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

The document on federalregister.gov PDF

Other documents from the Internal Revenue Service

Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in July 2024

Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.