The U.S. IRS has issued final regulations providing Guidance Under Section 367(b) Related to Certain Triangular Reorganizations and Inbound Nonrecognition Transactions (TD 10004), published in the Federal Register on 18 July 2024. The regulations finalize the proposed regulations issued in October 2023 to implement the regulations announced and described in the following notices, with modifications: Notice 2014-32: Treatment of Property Used To Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations; and Notice 2016-73: Treatment of Certain Triangular Reorganizations Involving Foreign Corporations; Amount of Income Inclusion in Certain Inbound Nonrecognition Transactions. The above notices are obsolete as...