{"abstract":"This document contains proposed regulations addressing transactions described in section 367(b) of the Internal Revenue Code (section 367(b) transactions). A section 367(b) transaction includes a corporate reorganization, liquidation, or division involving one or more foreign corporations. The proposed regulations address the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a section 367(b) transaction. The proposed regulations also address the allocation of certain tax attributes when a corporation distributes stock of another corporation in a section 367(b) transaction. This document also provides notice of a public hearing on the proposed regulations.","action":"Notice of proposed rulemaking and notice of public hearing.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2000/11/15/00-28950.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26}],"citation":"65 FR 69138","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests to speak (with outlines of oral comments) at a public hearing scheduled for March 13, 2001 must be received by February 20, 2001.","disposition_notes":null,"docket_ids":["REG-116050-99"],"dockets":[],"document_number":"00-28950","effective_on":null,"end_page":69182,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2000/11/15/00-28950.xml","html_url":"https://www.federalregister.gov/documents/2000/11/15/00-28950/stock-transfer-rules-carryover-of-earnings-and-taxes","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/00-28950?publication_date=2000-11-15","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2000-11-15/00-28950/mods.xml","not_received_for_publication":null,"page_length":45,"page_views":{"count":1046,"last_updated":"2026-09-21 00:15:04 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2000-11-15/pdf/00-28950.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":null,"publication_date":"2000-11-15","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2000/11/15/00-28950.txt","regulation_id_number_info":{"1545-AX65":{"issue":"200404","html_url":"https://www.federalregister.gov/regulations/1545-AX65/stock-transfer-rules-carryover-of-earnings-and-taxes","title":"Stock Transfer Rules--Carryover of Earnings and Taxes","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200404&RIN=1545-AX65&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-AX65"],"regulations_dot_gov_info":{"checked_regulationsdotgov_at":"2011-02-27T16:46:32Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":69138,"subtype":null,"title":"Stock Transfer Rules: Carryover of Earnings and Taxes","toc_doc":"Earnings and taxes carryover","toc_subject":"Income taxes:","topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":65}