IRS to Make Some Tax Exceptions For Reorganizations Into US (2)

The Treasury Department and the IRS plan to issue proposed regulations that tweak rules applied to transactions of US real property interests.

In Notice 2025-45 released Tuesday, the IRS stated its intent to revise rules that govern foreign-owned companies’ asset reorganization.

The agencies said that the rules governing US real property transactions may impede companies from redomiciling in the US.

For example, if a foreign company that holds a US real property interest wants to become an American company for valid non-tax business reasons, that transaction would be subject to tax under Section 897(d) or (e), when it could ...