Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations

الملخص

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations revising the rules under section 367(a) with respect to certain transfers of stock or securities of domestic corporations by United States persons pursuant to the corporate organization, reorganization or liquidation provisions of the Internal Revenue Code. The text of those temporary regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.