Final regulations finalize proposed regulations released in October 2023 without substantive change
The U.S. Treasury Department and IRS today released final regulations (T.D. 10004) providing guidance under section 367(b) relating to certain triangular reorganizations and inbound nonrecognition transactions. The final regulations specifically address:
Proposed regulations were published in October 2023 addressing these issues and proposing the regulations announced and described in Notice 2014-32 and Notice 2016-73, with modifications.
The final regulations, which are effective today, July 17, 2024, finalize the proposed regulations released in October 2023 without substantive change.