Treasury press release: Regulations to be Issued on Certain Triangular Reorganizations Involving Foreign Corporations: “The Department of the Treasury today issued a notice that announced that the Treasury Department and the Internal Revenue Service will issue regulations under section 367(b) of the Internal Revenue Code (Code) to address certain triangular reorganizations under section 368(a) involving foreign corporations. The notice states responds to comments and requests for guidance regarding certain triangular reorganizations that are designed to avoid U.S. tax, including tax on the repatriation of a subsidiary’s earnings.”
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