On 16 December 2016, Final Regulations (TD 9803) were published in the U.S. Federal Register concerning the treatment of certain transfers of property by U.S. persons, including foreign goodwill and going concern value, to foreign corporations in non-recognition transactions described in section 367 of the Internal Revenue Code (the Code). The regulations are effective the date they were published. The following is the summary/background as provided with the Final Regulations (TD 9803) as published. --- This document contains final regulations issued under sections 367 and 6038B of the Code. Temporary regulations were published on May 16, 1986 (TD 8087, 51...