T.D. 9400 contains final and temporary regulations under Section 367(b). The temporary regulations implement the rules described in Notice 2006-85 and Notice 2007-48. The regulations affect corporations engaged in certain triangular reorganizations involving one or more foreign corporations.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 367.—Foreign SUPPLEMENTARY INFORMATION: or funding S is to avoid the adjustments to Corporations be made by the regulations. Background
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