The final regulations adopt the October 2023 proposed regulations without any substantive changes.As it relates to cross-border triangular reorganizations, the final regulations adopt the modifications to IRC Section 367(b) regulations proposed in Notice 2014-32, as modified by Notice 2016-73.As it relates to the inbound nonrecognition transactions, the final regulations provide a taxpayer-friendly modification to the guidance in Notice 2016-73 by limiting the scope of the "excess asset basis" rules.In a departure from Notice 2016-73, the final regulations treat the foreign acquired corporation in an inbound nonrecognition transaction as receiving a deemed distribution under IRC Section 301. The United States (US) Department...