On October 6, 2023, the IRS published proposed regulations that were announced and described in Notice 2014-32 and Notice 2016-73 with certain modifications. These proposed regulations relate to the treatment of property used to acquire corporate parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations. The proposed regulations address the consequences to persons who receive parent stock or securities pursuant to such reorganizations as well as the treatment of certain subsequent inbound nonrecognition transactions following such reorganizations and certain other transactions.
The proposed 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. A more robust article discussing these proposed regulations is forthcoming.
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