Friday, April 25, 2014
The IRS today released Notice 2014-32, 2014-20 I.R.B. ___ (May 12, 2014):
Notice 2014-32 announces modifications and clarifications to the regulations under section 367(b) of the Internal Revenue 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”). The notice 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). Further, the notice clarifies the application of the anti-abuse rule.
(Hat Tip: Brian Davis)