{"abstract":"This document contains proposed amendments to the regulations under section 367 relating to certain transfers of stock involving foreign corporations in transactions governed by section 304. Specifically, these proposed regulations provide that if, pursuant to section 304(a)(1), a U.S person is treated as transferring stock of a domestic or foreign corporation to a foreign corporation in exchange for stock of such foreign corporation in a transaction to which section 351(a) applies, such deemed section 351 exchange is not a transfer to a foreign corporation subject to section 367(a). These proposed regulations also provide that if, pursuant to section 304(a)(1), a foreign acquiring corporation is treated as acquiring the stock of a foreign acquired corporation in a transaction to which section 351(a) applies, such deemed section 351 acquisition is not an acquisition subject to section 367(b).","action":"Notice of proposed rulemaking.","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/2005/05/25/05-10267.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26}],"citation":"70 FR 30036","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by August 23, 2005.","disposition_notes":null,"docket_ids":["REG-127740-04"],"dockets":[],"document_number":"05-10267","effective_on":null,"end_page":30040,"executive_order_notes":null,"executive_order_number":null,"explanation":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2005/05/25/05-10267.xml","html_url":"https://www.federalregister.gov/documents/2005/05/25/05-10267/application-of-section-367-in-cross-border-section-304-transactions-certain-transfers-of-stock","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/05-10267?publication_date=2005-05-25","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2005-05-25/05-10267/mods.xml","not_received_for_publication":null,"page_length":5,"page_views":{"count":693,"last_updated":"2026-04-04 16:15:04 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2005-05-25/pdf/05-10267.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":null,"publication_date":"2005-05-25","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2005/05/25/05-10267.txt","regulation_id_number_info":{"1545-BD46":{"issue":"200404","html_url":"https://www.federalregister.gov/regulations/1545-BD46/application-of-sections-304-b-6-and-367-in-cross-border-section-304-transactions","title":"Application of Sections 304(b)(6) and 367 in Cross Border Section 304 Transactions","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200404&RIN=1545-BD46&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BD46"],"regulations_dot_gov_info":{"checked_regulationsdotgov_at":"2011-11-12T16:17:54Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":30036,"subtype":null,"title":"Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign Corporations","toc_doc":"Section 367 stock transfers involving foreign corporations in transactions governed by section 304","toc_subject":"Income taxes:","topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":70}