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Article: IRS Issues Final Regulations Addressing Gain Recognition Agreements.
- Article from:
- Mondaq Business Briefing
- Article date:
- March 30, 2009
CopyrightCOPYRIGHT 2009 Mondaq Ltd. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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The new 367(a) regulations amend the 1997 rules and are generally favorable for taxpayers.
On February 11, 2009, the Internal Revenue Service (IRS) issued final regulations under section 367(a) addressing gain recognition agreements (GRAs) filed by U.S. persons with respect to transfers of stock or securities to foreign corporations. The final regulations revise and broaden temporary regulations issued in 2007 and amend the 1997 regulations.
The final regulations are generally taxpayer favorable, expanding the types of transactions that will not be treated as "triggering" existing GRAs. Additionally, the final regulations provide taxpayers with an ...