The Internal Revenue Service has issued final regulations restricting multinational corporations from bringing net built-in losses from abroad into the U.S.

The final regulations in TD 9633 apply to certain tax-free transfers of loss property under Section 362(e)(2) of the Tax Code, which was enacted as part of the American Jobs Creation Act of 2004. The final rules essentially echo those in proposed regulations that were issued in 2006, but with some revisions to clarify the structure and framework to better align with those in Section 362(e)(1), along with additional examples to illustrate how they would apply.

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