IRS T.D.: Corrections to Transfers of Property by Domestic Corporation to Foreign Corporation (IRC §367)

Corrections to final regulations that apply to transfers of certain property by a domestic corporation to a foreign corporation in certain nonrecognition exchanges, or to distributions of stock of certain foreign corporations by a domestic corporation in certain nonrecognition distributions, released August 19. The authority citation for Treasury Regulation Section 1.367(a)-3 states that paragraph (g)(1)(v)(A) and (B) are being added correcting the original March 19, 2013 publication stating that the paragraphs were being amended. In addition, Treas. Reg. Section 1.367(a)-7(f)(10) is removing “1.367(a)-1T(d)(4)” and replacing it with “1.367(a)-1(d)(4).” [T.D. 9614, RIN 1545-AM97, 85 Fed. Reg. __ (Aug. 20, ...