13. 10. Treas. Reg. §1.367(b)-4(b)(1)(i). 11. Treas. Reg. §1.367(b)-4(b)(1)(i). 12.

1.367 (b)-12.] amount has been attributed pursuant to nrm 1 in_9nni l § 7.367 (b)-

Jun 7, 2011 . 1.367(b)-10 and apply to transactions occurring after May 16, 2011. The final

May 17, 2011. final regulations are renumbered under Reg. section 1.367(b)-10. . and to

26 CFR 1.367(b)-13 - Special rules for determining basis and holding period. .

Application of Section 367 to Section 304 Transactions. Notice 2012-15. 10 . .

Nov 30, 2007 . implicate the current rules under §1.367(b)-5, because a . CFC earnings and

JUNE 1, 2011. “Killer B” Regulations Finalized. Reg. Section 1.367(b)-10.

May 8, 2008 . (e)(1)(iii) of this section make the election described in §1.367(a)-8T(b)(1)(vii).21.

action. Accordingly, under §1.367(b)-7(d), for- eign surviving . §1.367(b)–12

corresponding rules of §1.367(a)–8T (see . or before August 10, 2009. . . 10,

1.367(b)-3(b)(3)(ii), Example 1 (CFC Inbound Section 332 Liquidation With . ..

1.367(a)-3(a)(2)(iv) and added a separate priority rule under 1.367(b)-10(a)(2)(iii)

The exceptions described in § 1.367(a)-3(b)(1) and (c)(1) shall not apply to a

May 11, 2005 . See §1.367(a)–3(b)(2)(ii) for an illustration of the interaction of section . The

Jun 13, 2011 . 1.367(b)-10 and apply to transactions occurring after May 16, 2011. The final

Apr 29, 2010 . 26 CFR Ch. I (4–1–10 Edition). § 1.367(b)–4T shall be determined pursuant to

May 18, 2011 . Although the 2008 regulations were numbered under § 1.367(b)–14, the final

Dec 30, 2011 . section 381(b) and Treas. Reg. งง 1.381(b)-1(a)(2) and 1.367(b)-2(f)(4). 10)

26 CFR 1.367(b)-3T - Repatriation of foreign corporate assets in certain .

Apr 29, 2010 . 366. 26 CFR Ch. I (4–1–10 Edition). § 1.367(b)–5. §1.367(b)–5 Distributions of

USP also complies with the notice requirement under § 1.367(b)- 1(c). In year 2,

1.367(b)-12.] DIT.D. 8937,1-10-2001.] [Reg.§1.367(b)-131 §1.367(b)-13. Special

Jun 13, 2011 . Reg. § 1.367(b)-10(b)(1)]; or; (2) in a situation where the subsidiary buys its .

May 18, 2011 . The final regs largely adopt proposed regs that were published on May 27, 2008.

Aug 8, 2011 . In this situation, the final regulations would apply to the transaction. Under the

10. Section 1.367(b)-8 is added to read as follows: (E) Calculation of PC's

May 23, 2011 . priority rules in Treas. Reg. Section. 1.367 a!%3 a! and Treas. Reg. Section 1.367

May 2, 2011 . graph (e) of this section applies to transfers occurring on or after Feb- ruary 10,

Apr 1, 2009 . Under § 1.367(b)-2(d)(2)(iii) , the $10 of gain recognized by FC increases its

26 CFR 1.367(b)-4 - Acquisition of foreign corporate stock or assets by a . that

1.367(b)-12 Subsequent treatment of amounts attributed or included in income. .

May 27, 2011 . regulations section 1.367(b)-10 on triangular reorganizations involving foreign

Jun 23, 2011 . The US Treasury Department and the Internal Revenue Service have issued

Jan 4, 2012 . S 1.367(a)-9T(b) concerning the application of section. 367(a) to certain . Reg. $

Apr 29, 2010 . 26 CFR Ch. I (4–1–10 Edition). § 1.367(b)–0. § 1.367(b)–0 Table of contents.

. by Jasper L. (Jack) Cummings | Topic(s): Corporate – Federal. Treasury issued

1.367(b)-4T Acquisition of foreign corporate stock or assets by a foreign . . (e) of

See §1.367(b)–9 for special rules governing reorganizations described in . ..

Oct 10, 2011 . §1.367(b)-10. 3 However, as discussed in greater detail below, the Final Regu-

10%. Liquidating. Distribution. 100%. 90%. 10%. Reg. 1.367(b)-1(b)(2), Example.

Nov 30, 2007 . Section 1.367(b)-8(b) provides that the rules of §1.312-10. generally apply to

Under §1.367(b)–2(d)(2)(iii), the $10 of gain recognized by FC increases its

1.367(b)-10 Acquisition of parent stock or securities for property in triangular

Apr 1, 2009 . See § 1.367(b)-9 for special rules governing reorganizations described in section

The proposed regulations under §1.367(b)-8 balance the §1.312-10 rules and

May 31, 2011 . §1.367(b)-10(b)(5). 4 In general, §368(a)(1)(A) provides that a reorganization

Nov 1, 1991 . OVERVIEW New proposed regulations under section 367(a) and (b) of the . 10

“Prop. Reg. 1.367(b)-2(II(9). “Prop. Reg. 1.367(b)-2(|I(10). 1sProp. Reg. 1.367(b)-

Jun 13, 2011 . Although the 2008 regulations were numbered under §1.367(b)-14, the final

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