KPMG report - Non-recognition treatment on outbound transfers under section 367 

June 9: Corporate taxpayers that engage in cross-border business may qualify for non-recognition treatment on outbound transfers.

In certain outbound transfers, if an exchanging U.S. shareholder does not remain subject to section 1248 after a reorganization, the shareholder may have to recognize dividend income equal to the “section 1248 amount.”

A report prepared by KPMG tax professionals discusses helpful guidance in the final regulations issued under section 367(b) regarding the status of a shareholder as a section 1248 shareholder in certain reorganizations.

Read a June 2014 report [PDF 207 KB] prepared by KPMG LLP: What’s News in Tax: Outbound Non-Recognition Transactions—Final Section 367 Regulations Provide Guidance (Part 2)

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