The Notice defines a "covered inbound transaction" to include IRC Section 332 liquidations and certain asset reorganizations described in IRC Section 368(a)(1).Stock ownership requirements and other limitations in the Notice disqualify specific types of transactions from qualifying as covered inbound transactions.Taxpayers may rely on this guidance for transactions completed before the issuance of forthcoming proposed regulations, subject to certain conditions. In Notice 2024-16 (Notice), issued December 28, 2023, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) allow domestic acquiring corporations in certain inbound liquidations and asset reorganizations (covered inbound transactions) to determine under IRC Sections 334(b)...