Section 1.367(b)-2(d)(3) also issued under 26 U.S.C. 367(b)(1) and (2).* * *

Preview document Reg. Sec. 1.367(b)-3: Repatriation of foreign corporate assets

§1.367(a)-3 384, Reg. §1.863-3 71-72, 80 386-387 Prop. Reg. §1.863-8 80 Reg.

Feb 16, 2012 . Section 1.367(b)-3 and -8. In this respect, as described by the Notice, the US

See §1.367(a)–3(b)(2) for transactions subject to the concurrent application of . .

Apr 1, 2009 . (B) If a foreign corporation transfers assets to a domestic corporation in a

May 2, 2011 . $30 as provided in §1.367(b)–3(b)(3)(i), DC in- stead elects taxable exchange

May 23, 2011 . Section 1.367 b!%10. As a result, under the Treas. Reg. Section 1.367 a!%3 a!

(i) A shareholder described in §1.367(b)-3(b)(l) that realizes income in a

Sep 21, 2011 . 1.367(a)–3T(b) contains exceptions to the general rule of taxability for certain

Jun 13, 2011 . 1.367(a)-3, 1.367(b)-10. The regulations finalize the proposed regulations with

(3) The rules of paragraph (b)(l)(i) of this section that provide an exception . is

Jun 3, 2008 . The rules of §§ 1.367(b)-3 and 1.367(b)-4, as they apply to reorganizations

Jun 13, 2011 . Third, the priority rule is modified to clarify its application by providing separate

In lieu of the treatment prescribed by 1.367(b)3(b)(3)(i), an exchanging

Jun 23, 2011 . In general, Killer B transactions are triangular reorganizations involving . . 3

In the case of a foreign divisive transaction that includes a D reorganization, the

Nov 30, 2007 . Section 1.367(b)-3(d) and proposed §1.367(b)-3(f) provide further. rules

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

May 2, 2011 . 1.367(b)–3. (see also §601.601(d)(2) of this chapter). The term pre-1987 section

26 C.F.R. § 1.367(b)-3 Repatriation of foreign corporate assets in certain

See §1.367(a)–3(b)(2) for transactions subject to the concurrent application of

Apr 21, 2008 . The rules of §§ 1.367(b)-3 and 1.367(b)-4, as they apply to reorganizations

Feb 1, 2007 . D. Removal of Rule under §1.367(b)-2(d)(3)(ii) Limiting Amounts . Pursuant to §

951(b)) then they must include the all E&P amount in income. Reg. 1.367(b)-3(b)(

Thus, under sections 243(e) and § 1.367(b)-2(j)(3), $62.50 of the distribution is

367 Interest. Prior § 1.367(a)-8(b)(3)(iii). Section367Interest. Section 367 Interest.

(ii) The all earnings and profits amount described in § 1.367(b)-3(b)(3)(i) with

Feb 14, 2012 . §367(a) and the regulations thereunder, including the exceptions described in.

under. § 1.367(b)–3(b) is greater than the amount of gain in such stock subject to

See 1.367(b)4(d). (3) Post-exchange earnings and profits. Any earnings and

The rules of §§1.367(b)–3 and 1.367(b)–4, as they apply to reorganizations

(e) (3) Divisive D reorganization with a preexisting controlled corporation. — In

Jun 7, 2011 . §1.367(b)-10 do not apply if: (1) the parent is a foreign corporation; (2) the

1.367(a)–3T(b) contains exceptions to the general rule of taxability for certain

301.7701-2(a), (b); -3(a), (c)(1)(i)-(iii), (c)(2), (g); 1.954-2(e)(3). Dolan: ¶¶ 2.01 .

Section Remove Add 1.367(a)-3(d)(3), Example l(ii), fourth sentence . Example l

(i) A shareholder described in §1.367(b)–3(b)(1) that realizes income in a

Jan 5, 2005 . Reg. sec. 1.367(a)-3, "Treatment of transfers of stock or securities to foreign

May 10, 2005 . 1.367(b)-3 Repatriation of foreign corporate assets in certain nonrecognition

and (b). All of the requirements of Treas. Reg. §1.367(a)-3(b)(1) are satisfied, and

Treas. Reg. § 1.367(b)-2(e)(3)(i). 15. Treas. Reg. § 1.367(b)-2(e)(3)(ii). 16. Treas.

This notice provides guidance under section 367(a) and (b) of the Internal

in three parts. Prop. Reg. 1.367(b)-3 addresses inbound asset reorganizations;

Apr 1, 2009 . (3) Interaction with The basis increase provided in § 1.367(b)-2(e)(3)(ii) shall not

Apr 1, 2009 . See § 1.367(a)-3(b)(2) for transactions subject to the concurrent application of

May 8, 2008 . 1.367(a)-3(b) (transfers of foreign stock or securities) and -3(c) (transfers of

1.367(b)-3(a) provides that special rules apply "to an acquisition by a domestic

Apr 1, 2009 . (a) Scope. This section applies to an acquisition by a domestic corporation (the

(1) In general. (2) Persons subject to section 367(b) notice. (3) Time and manner

Sitemap