Internal Revenue Service May 19, 2011 – Federal Register Recent Federal Regulation Documents

Treatment of Property Used To Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations
Document Number: 2011-12279
Type: Rule
Date: 2011-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under section 367 of the Internal Revenue Code (Code) relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations. The regulations finalize proposed regulations and withdraw temporary regulations published on May 27, 2008 (TD 9400). The regulations affect corporations that engage in certain triangular reorganizations involving one or more foreign corporations.