Sean Foley On February 10 2009, the Treasury department and IRS released temporary regulations (T.D. 9444) modifying the section 367 regulations by applying sections 367(a) and (b) to certain international section 304(a)(1) transactions, commonly referred to as cross-chain stock sales. The temporary regulations apply to transfers or distributions occurring on or after February 11 2009.
March 31 2009