The US IRS today announced that it will modify tax regulations under section 367 to address triangular reorganizations involving foreign corporations where a subsidiary acquires its parent’s stock for property and uses that stock to acquire a target corporation.
The announcement, Notice 2016-73, also states that IRS will modify the section 367 regulations with respect to the “all earnings and profits” amount that must be included in income as a result of certain inbound asset acquisitions that repatriate “excess asset basis.”
See:
Be the first to comment