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Final §367(b) Regulations Issued. On August 8, 2006, the IRS and Treasury issued final regulations under §367(b) addressing the carryover of tax attributes in inbound and foreign-toforeign §381 transactions.1 The regulations finalize most of the proposed §367(b) regulations issued in November 2000. 2 The regulations do not however, address the portions of the proposed rules for corporate divisions, 3 and also do not address previously taxed income (PTI) accounts.
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