Finanse publiczne · 08/04/2016

IRS Withdraws Portions of Proposed Rules on Section 367 and Section 351 Exchanges

The IRS has withdrawn parts of two proposed rules related to Section 367 and Section 351 exchanges, which were published in the Federal Register on February 11, 2009, and January 17, 2014, respectively. The withdrawn portions pertain to the application of Section 367(b) to transactions described in Section 304(a)(1) and the identification of certain foreign corporation stock in calculating ownership for purposes of determining a surrogate foreign corporation under Section 7874.