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federal_register: 2024-15232

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
2024-15232 Guidance Under Section 367(b) Related to Certain Triangular Reorganizations and Inbound Nonrecognition Transactions Rule This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to such reorganizations; and the treatment of certain subsequent inbound nonrecognition transactions following such reorganizations and certain other transactions. The final regulations affect corporations engaged in certain triangular reorganizations involving one or more foreign corporations, certain shareholders of foreign corporations acquired in such reorganizations, and foreign corporations that participate in certain inbound nonrecognition transactions. 2024-07-18 2024 7 https://www.federalregister.gov/documents/2024/07/18/2024-15232/guidance-under-section-367b-related-to-certain-triangular-reorganizations-and-inbound-nonrecognition https://www.govinfo.gov/content/pkg/FR-2024-07-18/pdf/2024-15232.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that...  

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