Notice 2024-16: Guidance Related to Section 961 and Certain Inbound Nonrecognition Transactions

Notice 2024-16 announces that Treasury and the IRS intend to issue proposed regulations that will address certain basis consequences of internal restructuring transactions in which a U.S. corporation acquires stock of a controlled foreign corporation (?CFC?) from another CFC. In particular, the notice announces rules under which basis provided under section 961(c) in stock of a second-tier CFC held by a first-tier CFC will be transferred to a U.S. corporation that acquires the second-tier CFC from the first-tier CFC in a liquidation described in section 332 or an asset reorganization described in section 368(a)(1).

Notice 2024-16 will be in IRB 2024-5, dated January 29, 2024.

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