The US Treasury Department and Internal Revenue Service (IRS) have corrected errors in final regulations on property transfers and stock distributions in cross-border reorganizations. The corrections regard, in particular, the treatment of transfers of stock or securities to foreign corporations in outbound transactions. The final regulations (TD 9614) that are the subject of this correction were issued in 2013 under section 367 of the US Internal Revenue Code.
The corrections were published in the Federal Register on 20 August 2020 (85 FR 51346) and are effective on that date.