Wednesday, April 30, 2014
Recently, the IRS released a notification that clarifies section 367(b) in the Internal Revenue Code. The section is related to the treatment of property used to get stocks in particular triangular reorganizations involving foreign corporations. The notice gets rid of the contribution model under the existing rules and changes the priority rules.
See Paul Caron, IRS Shuts Down Killer B Repartriations (Again), Tax Prof. Blog, Apr. 25, 2014.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.