N-2016-73: Treatment of Certain Triangular Reorganizations Involving Foreign Corporations; Amount of Income Inclusion in Certain Inbound Nonrecognition Transactions

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December 2, 2016

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Issue Number: N-2016-73

Inside This Issue

Notice 2016-73 announces the modification of rules under section 367 that would address certain triangular reorganizations involving foreign corporations where a subsidiary acquires its parent’s stock for property and uses that stock to acquire a target corporation. The rules would also modify the “all earnings and profits” amount that must be included in income as a result of certain inbound asset acquisitions that repatriate “excess asset basis.”

Notice 2016-73 will be in IRB 2016-51, dated December 19, 2016.

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