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

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This document contains final regulations relating to certain transfers of stock or securities of domestic corporations by United States persons to foreign corporations pursuant to the corporate organization, reorganization, or liquidation provisions of the Internal Revenue Code. These final regulations modify the rules contained in the temporary regulations to reflect certain taxpayer comments received in response to those temporary regulations. This action is necessary to provide the public with guidance to comply with the Tax Reform Act of 1984.