The Internal Revenue Service is modifying and clarifying the regulations under Section 367(b) of the Tax Code relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations, colloquially referred to as the “Killer B regulations,” to close loopholes in the anti-abuse rules.
Notice 2014-32 eliminates the deemed contribution model under the existing regulations. In addition, the notice modifies the amount of income and gain taken into account for purposes of applying the priority rules of Section 367(a) and (b).
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