Finanse publiczne · 24/06/2011

IRS Issues Final Regulations on Basis of Property Acquired in Nonrecognition Transactions

The Internal Revenue Service (IRS) has released final and temporary regulations under Section 956 of the Internal Revenue Code, clarifying the basis of property acquired by controlled foreign corporations in nonrecognition transactions intended to repatriate earnings and profits without U.S. income taxation. These regulations apply to U.S. shareholders of controlled foreign corporations acquiring U.S. property in such transactions.