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Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction

2013-11-12

Below is a chart of Rev. Rul. 67-192 in which the IRS held that section 367 applied to a transaction where a U.S. corporation contributed assets with built-in gains and losses to a foreign corporation. As a result, the built-in gains were recognized and the built-in losses were not.

The chart can be viewed as a PDF file here: Rev. Rul. 67-192

Tags: 351 Exchanges, Authority - Revenue Rulings, Charts - Situational Charts

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