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New temporary regulations consolidate rules for treatment of stock transfers to foreign corporations under sec. 367(a).: An article from: The Tax Adviser
Gary Melcher
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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on March 1, 1996. The length of the article is 2509 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: New temporary IRS regulations under IRC section 367(a) identify the limited instances when US persons may transfer US stock to foreign corporations without recognizing gain on the transfer. The transferor must own 50% or less of the transferee's stock after the transfer, must transfer 50% or less and, after Jan 1996, the transferee must meet a trade or business requirement. The transferor must also not be a 5% shareholder in the foreign corporation after the transfer or must sign a gain recognition deferral agreement. The new regulations relax the presumption of 50% ownership.
Citation Details
Title: New temporary regulations consolidate rules for treatment of stock transfers to foreign corporations under sec. 367(a).
Author: Arthur J. Dichter
Publication: The Tax Adviser (Magazine/Journal)
Date: March 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n3 Page: 141(4)
Distributed by Thomson Gale