The Treasury Department and IRS this afternoon released for publication in the Federal Register final regulations (T.D. 9760) concerning cross-border merger and acquisition (M&A) transactions. Today’s release finalizes regulations that were proposed in March 2013, and removes corresponding temporary regulations.
Today’s final regulations [PDF 248 KB], among other measures, eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations.
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