federal_register: E8-11647

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E8-11647 Treatment of Property Used To Acquire Parent Stock in Certain Triangular Reorganizations Involving Foreign Corporations Proposed Rule In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 367(b) of the Internal Revenue Code (Code) regarding certain triangular reorganizations. The regulations implement rules described in Notice 2006-85 and Notice 2007-48. The regulations primarily affect corporations engaged in certain triangular reorganizations involving one or more foreign corporations. The text of those regulations also serves as the text of these proposed regulations. 2008-05-27 2008 5 https://www.federalregister.gov/documents/2008/05/27/E8-11647/treatment-of-property-used-to-acquire-parent-stock-in-certain-triangular-reorganizations-involving https://www.govinfo.gov/content/pkg/FR-2008-05-27/pdf/E8-11647.pdf Treasury Department; Internal Revenue Service 497,254 In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 367(b) of the Internal Revenue Code (Code) regarding certain triangular reorganizations. The regulations implement rules...  

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