The US Treasury Department and the Internal Revenue Service (IRS) have issued final and temporary regulations (TD 9614) with guidance on property transfers and stock distributions in cross-border reorganizations under sections 367, 1248, and 6038B of the US Internal Revenue Code (IRC).
The new regulations adopt with modifications a portion of proposed regulations (REG-209006-89) issued on 20 August 2008. A portion of the 2008 proposed regulations is adopted, with modifications, in tempor…