PORTFOLIO

U.S.-to-Foreign Transfers Under Section 367(a) (Portfolio 919)

This Portfolio, U.S.-to-Foreign Transfers Under Section 367(a), examines the rules that apply to various forms of foreign corporate or partnership formations or restructurings under §367(a) and under related provisions such as §6038B. These rules sometimes require the recognition of gain with respect to transactions that otherwise generally could have qualified for nonrecognition of gain under provisions such as §§332, 351, 354, 361 or 721.

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DESCRIPTION

The Portfolio begins with a review of the scope and general operation of §367(a), describing the elements of transactions that are subject to it. It then reviews the application of §367(a) to outbound transfers of business property, including the significant exception for transfers of foreign business property. The portfolio also discusses outbound transfers of stocks and securities that would otherwise qualify for nonrecognition treatment, and the use of gain recognition agreements to defer the recognition of gain on such transfers. Finally, it concludes with a review of the special rules under §367(a)(5) for U.S.-to-Foreign Reorganizations, the reporting requirements under §6038B, and the anti-expatriation provisions of §7874, which overlap some of the rules in §367(a). The portfolio also includes Worksheets that reproduce the important legislative history from the Tax Reform Act of 1984, various IRS guidance, and a sample gain recognition agreement.
The objective of this Portfolio is to describe the intent and operation of §367(a) and related provisions, and to highlight various planning techniques used by taxpayers to cope with the rules in the context of particular types of transactions.


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AUTHORS

U.S.-to-Foreign Transfers Under Section 367(a) was authored by the following experts.
BRUCE N. DAVIS, ESQ.
Bruce N. Davis, Esq., B. A., University of Virginia (1980, high honors, Phi Beta Kappa); J.D., Harvard Law School (1983); LL.M. (in taxation), Southern Methodist University (1987); former Chairman, Subcommittee on §§338, 367 and 1491, Committee on Foreign Activities of U.S. Taxpayers, American Bar Association; Principal Special Assistant to the Associate Chief Counsel (International), Internal Revenue Service (1988–1991); member of board of advisors of various international tax publications, and frequent speaker and writer on international tax issues.

TABLE OF CONTENTS

Detailed Analysis

I. Introduction

II. Scope and General Operation of § 367(a)(1)

Introductory Material

A. U.S. Person as the Transferor

1. Definition of U.S. Person

2. Transferor That Is Foreign or U.S. Partnership

a. Aggregate Approach

b. Basis Adjustments

(1) U.S. Partner's Basis in Partnership Interest

(2) Partnership's Basis in Stock of Transferee Foreign Corporation

(3) Transferee Foreign Corporation's Basis in Transferred Property

c. Determining a U.S. Partner's Share of Transferred Property

d. General or Limited Partnerships

e. Source and Character of Partner's Gain

3. Transferor That Is an Estate or Trust

a. Entity Approach for Estates and Non-Grantor Trusts

b. Aggregate Approach for Grantor Trusts

B. Transfer of Property to a Foreign Corporation

1. Terms Defined by Cross-Reference

2. Using Alternative Transactions to Avoid § 367(a)

3. Certain Deemed Transfers of Property

a. Section 368(a)(1)(F) Reorganizations

b. Deemed Change in Domestic Status

(1) Termination of § 1504(d) Election

(2) Termination of Domestic Status Under Other Special Rules

c. Reclassification of Foreign Entity as Corporation

4. Limited Applicability to Transfer of Intangible Property

a. General Preemption by § 367(d)

b. Definition of Intangible Property

c. Limitations on General Preemption by § 367(d)

5. General Inapplicability to Transfer to FSC

a. Used to Generate Exempt Income

b. Export Property

c. Suitable for FSC Office Use

d. Anti-Conduit Rule

C. Actual Exchanges and Deemed Exchanges Under § 367(c) or § 367(f)

1. Deadwood References to § 332 and § 355

2. Section 367(c)(2) Deemed Exchanges

a. Background

b. Abegg and Lessinger

c. Application of § 367(c)(2) to Outbound Transfers

(1) Contribution to Capital

(2) Voting Control

(3) Comparison to § 351 Control

(4) Whether the Deemed Stock Is Considered Voting Stock

(5) Whether § 367(c)(2) Can Result in Taxable Deemed Exchange Outside Scope of § 367(a)

(6) Bifurcation of Hybrid Transactions

3. Section 367(f) Deemed Exchanges

4. Cross-Reference to Special Rules for Outbound Stock Transfers

D. Gain Limitation

E. Nonrecognition of Loss

F. Character and Source of Gain

1. Ordinary or Capital Treatment

2. Source and Limitation Category

G. Adjustments to Basis, Earnings and Profits, and Other Items

III. U.S.-to-Foreign Transfers of Tangible Property Under § 367(a)

Introductory Material

A. The Foreign Business Asset Exception

1. Trade or Business Requirement

a. Facts and Circumstances Test

b. Independent Economic Enterprise

2. Active Conduct Requirement

a. Facts and Circumstances Test

b. Substantial Managerial and Operational Activities

(1) Activities Carried Out by Officers and Employees

(2) Exclusion of Independent Contractor Activities

(3) Active Rents and Royalties

3. Foreign Conduct Requirement

a. Facts and Circumstances Test

b. Situs of Primary Activities and Assets

(1) General Ineligibility of U.S. Trade or Business

(2) Eligibility of Incidental U.S. Property

4. Use Requirement

a. Facts and Circumstances Test

b. Direct Relationship to the Trade or Business

c. Asset-by-Asset Determination

d. Special Rules for Leased Property

(1) Active Conduct of Leasing Business

(2) No U.S. Use

(3) Transferee's Need

(4) De Minimis Rules

(a) Idle Capacity

(b) Ten-Percent Real Property Lease

(5) Special Rules if U.S. Transferor Is Lessor

(6) Special Rules for U.S. Depreciated Property

e. Special Rules for Mineral Properties

(1) Active Use of Working Interest

(a) Transferor's Business

(b) Active Negotiation

(c) Five-Percent Interest

(d) Transferor's Involvement in Operations

(e) Transferor's Involvement in Decisions

(f) Transferee's Use of Interest

(g) No Post-Transfer Farm Out or Disposition

(2) Working Interests to Be Used in Start-Up Operations

(a) Acquired by Transferor for Purpose of Transfer

(b) Active Negotiation

(c) Five-Percent Interest

(d) Transferee's Use of Interest

(3) Gain Recognition Agreement

(4) Qualification Under General Rules

(5) Royalty Interests

f. Compulsory Transfers

(1) Same-Country Use

(2) Transfer Is Compulsory

(3) Relationship to Taxable Transfer Rules

5. Post-Transfer Disposition of Transferred Property

a. Six-Month Presumption

b. Exception for Cascading Transfers

(1) Qualification Under § 351 or § 721

(2) Nature of Interest in Transferee

(3) Use Requirement Applied at Lower Tier

(4) Qualification of Initial Transfer Under § 351

(5) Interaction with § 367(a) Stock Transfer Rules

6. Transfer of Partnership Interest

a. Aggregate Approach

b. Basis Adjustments

(1) U.S. Partner's Basis in Stock of Transferee Foreign Corporation

(2) Transferee Foreign Corporation's Basis in Transferred Partnership Interest

(3) Partnership's Basis in Its Property

c. Determining a Transferor Partner's Share of Partnership Property

d. Special Rules for Certain Limited Partnerships

(1) Limited Partnership Interest

(2) Regularly Traded

(3) Established Securities Market

e. Source and Character of Partner's Gain

B. Property Ineligible for Foreign Business Asset Exception

1. Historical Background

2. Section 1221(a)(1) and (3) Property

3. Receivables and Similar Property

4. Foreign Currency Denominated Instruments

a. Gain Recognition Rule

b. Gain Limitation

c. Exception for Same-Country Instruments

d. Recognition of Exchange Gain or Loss Under § § 985 Through 989

5. Treatment of Intangible Property

6. Certain Leased Property

7. Certain Depreciated Property

a. U.S. Depreciated Property

(1) Depreciable or Depletable Property

(2) U.S. Use of Property

(3) Expanded Definition in Context of § 338 Election

b. Amount Subject to Recapture

(1) Property Used Wholly Within the United States

(2) Property Used Partly Within and Partly Outside of the United States

(3) Gain in Excess of Recapture Amount

C. Branch Loss Recapture Rule

1. Background: The IRS's Failed Attempt to Impose an Administrative Branch Loss Recapture Rule

a. Absence of Guidance in the 1968 Guidelines

b. Rev. Rul. 78-201

c. Taxpayers Prevail in Court

(1) Hershey

(2) Mars

(3) The IRS Capitulates

2. Branch Loss Recapture Under the Statute and Regulations

a. Existence of a Foreign Branch

(1) General Facts and Circumstances Test

(2) Automatic Branch Status for Treaty Permanent Establishment

(3) Irrelevance of Classification of U.S. Person

(4) Separate or Combined Foreign Branches

(5) Aggregation of Branches of Affiliated Transferors

(6) Comparison to Other Code Concepts

(a) Section 989(a) Qualified Business Unit

(b) Section 904(f)(3) Foreign Trade or Business Property

(c) Section 1503(d) Separate Unit

b. Amount of Recaptured Branch Losses

(1) Separate Computation for Ordinary and Capital Branch Losses

(2) Tax Benefit Rule

(a) Expired v. Unexpired Deductions and Credits

(b) Reduction for Branch Losses That Expire Unused

(c) Reduction for Non-Branch Losses That Expire Unused

(d) Ordering Rule for Losses

(e) Reduction for Foreign Tax Credits That Expire Unused

(f) Reduction for Investment Credits That Expire Unused

(3) Gain Limitation

(4) Effect of Not Transferring Certain Branch Assets

c. Character and Source of Recapture Income

(1) Ordinary or Capital Treatment

(a) Determination by Reference to Prior Losses

(b) Distinction from General Character Rule Under § 367(a)

(c) Determination of Character if Gain Limitation Applies

(d) Coordination with § 367(d)

(2) Source

(a) Treatment as Foreign Source

(b) Distinction from General Source Rule Under § 367(a)

(3) Effect on § 904 and § 907 Limitations

d. Intangible Branch Assets

(1) Foreign Goodwill and Going Concern Value

(2) Other Intangibles

e. Interaction with § 904(f) Recapture

f. Interaction with § 1503(d) Recapture

g. Incorporation of a Partnership

IV. U.S.-to-Foreign Transfers of Stock or Securities Under § 367(a)

Introductory Material

A. Background

1. Legislative Origins

2. Transfers of Stock or Securities Under the 1968 Guidelines

3. Movement to Objective Rules After Kaiser

a. The 1986 Temporary Regulations and Notice 87-85

b. The 1991 Proposed Regulations

c. The 1998 Final Regulations

B. Outbound Transfers of Stock or Securities Under the Regulations-Scope and Basic Framework

1. Exchanges to Which Regulations Do or Do Not Apply

a. General Scope

b. Foreign-to-Foreign Asset Reorganizations

c. Outbound Asset Reorganizations

d. Outbound § 361(c) Transfers

e. Recapitalizations

f. Section 304 Exchanges

g. Transfer of the Transferor's Own Stock or Securities

h. Indirect Transfers

i. Transfer to Foreign Hybrid Entity

2. Basic Framework of the 1998 Final Regulations

a. GRA Requirement for Five-Percent-or-Greater Shareholders

b. No GRA Requirement for Less-than-Five-Percent Shareholders

3. Avoiding the GRA Requirement

a. Check-the-Box Election

b. Outbound § 354 Exchange

c. Transfer to Foreign Hybrid Entity

C. The "Anti-Expatriation" Rule for Certain Transfers of Domestic Stock or Securities

1. Background of Expatriation Transactions

a. General Description and Certain Tax Aspects of Expatriation Transactions

b. General Description and Certain Tax Aspects of the Inversion Variation

c. Historic Background of § 367(a) Treatment of Expatriation Transactions

(1) The 1968 Guidelines

(2) Notice 87-85 and the 1991 Proposed Regulations

(3) Notice 94-46

(4) Regulations Implementing Notice 94-46

(5) The Search for Policy

2. Taxation of Expatriation Transactions Under § 367(a)

a. Fifty-Percent Restrictions

(1) Fifty-Percent Receipt Restriction

(a) Treatment of U.S. Transferors of Other Stock or Property

(b) Identifying Public Shareholders

(i) Ownership Statements

(ii) Compilation of Ownership Statements

(c) Indirect, Constructive, and Residual Ownership

(2) Fifty-Percent Control Group Restriction

(a) Treatment of U.S. Non-Transferors

(b) Identifying Five-Percent Shareholders

(c) Indirect, Constructive, and Residual Ownership

(3) Pre-Transaction Value Reduction Techniques

b. Active Trade or Business Requirement

(1) Three-Year Requirement

(a) Meaning of "Active Trade or Business Outside the United States"

(b) Eligibility of Acquired Business

(c) Meaning of "Qualified Subsidiary"

(d) Meaning of "Qualified Partnership"

(2) Intention Requirement

(3) Substantiality Test

(a) Recently Acquired Assets

(i) Passive Assets

(ii) Avoidance Purpose Assets

(iii) Assets of Domestic Transferred Corporation or Affiliate

(b) Qualified Subsidiary or Partnership

(4) Substantial Compliance PLR

c. Gain Recognition Agreement Requirement

d. Reporting Statement Requirement

(1) Filing by Transferred Domestic Corporation Rather than Transferor

(2) Meaning of "Timely Filed"

(3) Contents of Reporting Statement

(a) Transaction Description

(b) Aggregate Percentage of Transferee Stock Received

(c) Vestigial Stock

(d) Control Group

(e) List of Insiders

(f) Active Business Statement and Description

(g) Statement on Intention Restriction

(h) Substantiality Test Statement and Documentation

(i) Addition Method Statement

(ii) Subtraction Method Statement

e. No CFC Exception

f. Transfer of Domestic Corporation's Own Stock or Securities

3. Techniques to Avoid Anti-Expatriation Rules

a. Domestic Stock Recapitalizations

b. Outbound Asset Reorganizations

c. Transfer to Foreign Hybrid Entity

D. Decontrolling Transfers

1. Taxation Rule Under Notice 87-85

2. No Special Rule Under 1998 Final Regulations

E. Interaction with § 367(b)

1. Section 367 Policies in Outbound Transfers of Stock or Securities

2. The Statutory Priority Rules

a. The § 367(b)(1) Kick-Out

b. The § 367(a)(2) Kick-Out

c. The § 367(a)(5) Kick-Out

3. Coordination Rules Under the Regulations

F. Gain Recognition Agreements

1. Amount and Reporting of Gain, Tax, and Interest

a. Amount of Gain Recognized

b. Amended Return or Interest-Charge GRA Election

(1) Treatment if No GRA Election Is Made

(2) Treatment if GRA Election Is Made

(3) Avoidance of GRA Interest Charge

c. Basis Adjustments

(1) Transferee Foreign Corporation's Basis

(2) U.S. Transferor's Basis

(3) Other Basis Adjustments

d. "Protective" or "Erroneous" GRAs

2. Term of GRA and Early Termination Events

a. Five-Year Rule

b. Early Termination of GRA

(1) Complete Disposition of Transferee Stock

(2) Partial Disposition of Transferee Stock

(3) Special Rule for Certain Distributions by Transferee Foreign Corporation

(4) Special Rule for Certain Domestic Transferred Corporations

c. Early Termination Planning to Avoid Interest Charge

3. Determining Whether There Is a GRA Triggering Event

a. Disposition of Transferred Corporation Stock or Securities

b. Disposition of Transferred Corporation's Assets

c. Disposition of Stock of Transferee Foreign Corporation

d. U.S. Transferor Deconsolidation

e. U.S. Transferor Consolidation

f. U.S. Transferor Becomes NRA

g. Individual Dies, or Trust or Estate Goes Out of Existence

(1) Retention of Assets

(2) Provision of Security

(3) PLR Provides for Successors

h. Noncompliance with GRA Rules

4. Certain Nonrecognition Exchanges That Do Not Trigger GRA

a. Nonrecognition Exchanges Described in § 351, § § 354/368(a)(1)(B), or § 721

(1) Exchange by U.S. Transferor

(2) Exchange by Transferee Foreign Corporation

(a) No Recognition of Gain

(b) New GRA

(3) Exchange by Transferred Corporation

b. Nonrecognition Exchanges Described in § 332 and § 337

(1) Liquidation of U.S. Transferor

(a) Distributee Is U.S. Corporation

(b) New GRA

(2) Liquidation of Transferee Foreign Corporation

(3) Liquidation or Upstream Reorganization of Transferred Corporation

c. Recapitalization Described in § 368(a)(1)(E) or § 1036 Exchange

(1) Recapitalization or § 1036 Stock Exchange of U.S. Transferor

(2) Recapitalization or § 1036 Stock Exchange of Transferee Foreign Corporation

(3) Recapitalization or § 1036 Stock Exchange of Transferred Corporation

d. Certain Asset Reorganizations

(1) Asset Reorganization of U.S. Transferor

(a) Domestic Acquiring Corporation

(b) New GRA

(2) Asset Reorganization of Transferee Foreign Corporation

(a) No Recognition of Gain

(b) Foreign Acquiring Corporation

(c) New GRA

(3) Asset Reorganization of Transferred Corporation

(a) No Recognition of Gain

(b) New GRA

e. Deferred Intercompany Disposition of Transferee Stock

f. § 338(g) Deemed Asset Sale

g. Catch-All Exception for Certain Other Nonrecognition Dispositions

5. Procedural Aspects of GRAs

a. Format of GRA

(1) Introductory Statement

(2) Description of Transferred Property and Other Information

(a) General Requirements

(b) Additional Requirements for Partnership Transfers or Indirect Transfers of Other Property

(3) Agreement to Recognize Gain

(4) Arrangements for Notification

(5) New GRAs

(6) GRA Election

(7) Triggering Event

b. Signature

c. Manner and Date of Filing

d. Waiver of Limitations Period

(1) Form of Waiver

(2) Term of Waiver

(3) Other Terms

(4) Signature

(5) Other Rules for Extension of Limitations Period

e. Annual Certifications

6. Failure to Comply

7. Section 6038B Reporting of Outbound Stock Transfers

a. Five-Percent-or-Greater Shareholders

(1) GRA Is Filed

(2) Tax-Exempt Transferor

(3) Taxable Transfer That Is Properly Reported

(4) Section 83 Deemed Transfer Not Exceeding $100,000

b. Less-Than-Five-Percent Shareholders

(1) Nonrecognition Transfer

(2) Tax-Exempt Transferor

(3) Taxable Transfer That Is Properly Reported

(4) Section 83 Deemed Transfer Not Exceeding $100,000

G. Indirect Transfers Under § 367(a)

1. Triangular Reorganizations

a. Forward Triangular Reorganization

(1) Indirect Stock Transfer

(2) Rev. Rul. 74-297

(3) Applying GRA Provisions

(4) Actual Outbound Asset Transfer

(5) Interaction with "Anti-Expatriation" Rule

b. Reverse Triangular Reorganization

(1) Indirect Stock Transfer

(2) Applying GRA Provisions

(3) Actual Outbound Asset Transfer

(4) Interaction with "Anti-Expatriation" Rule

c. Triangular "B" Reorganization

(1) Indirect Stock Transfer

(2) Applying GRA Provisions

(3) Interaction with "Anti-Expatriation" Rule

d. Triangular "C" Reorganization

(1) Indirect Stock Transfer

(2) Applying GRA Provisions

(3) Actual Outbound Asset Transfer

(4) Interaction with "Anti-Expatriation" Rule

2. Drop-Down Transactions

a. Asset Reorganization and Drop-Down

(1) Indirect Stock Transfer

(2) Partial Drop-Down

(3) Applying GRA Provisions

(4) Actual Outbound Asset Transfer

(5) Drop-Down into Domestic Controlled Corporation, and Interaction with § 367(a)(5) and "Anti-Expatriation" Rule

b. Cascading § 351 Transfers

(1) Indirect Stock Transfer

(2) Partial Drop-Down

(3) Applying GRA Provisions

(4) Actual Outbound Asset Transfer

(5) Drop-Down into Domestic Controlled Corporation, and Interaction with § 367(a)(5) and "Anti-Expatriation" Rule

3. No Indirect Transfer Rule Under § 367(b)

V. Special Rules for U.S.-to-Foreign Reorganizations Under § 367(a)(5)

Introductory Material

A. General Denial of Exception to Gain Recognition

1. Outbound Transfers Described in § 361(a) or (b)

2. Outbound Transfers Described in § 361(c)

B. Relief in Certain Cases of U.S. Corporate Ownership

1. U.S. Corporate Control Requirement

a. Cross-Reference to § 368(c)

b. Aggregation of Affiliated Group Members

c. Direct v. Indirect Ownership

d. Effect of Limited Base Erosion

2. Basis and Other Adjustments

a. Basis Rules Without Special Adjustments

b. Lesser of Outside or Inside Basis

c. Effect of Liabilities Assumed

d. Adjustment to Holding Period

3. Electivity of § 367(a)(5) Adjustments

4. Special Statement Required Under § 6038B

5. Proposed Regulations Under § 367(a)(5)

C. Pre-Transaction Restructuring to Satisfy § 367(a)(5) Requirements

D. Avoiding § 367(a)(5)

E. Closing of Taxable Year

VI. Reporting of § 367(a) Transfers Under § 6038B

Introductory Material

A. Required Information and Procedures

B. Penalties for Failure to Comply

1. Statutory Ten-Percent Penalty

2. Regulatory Ineligibility for Foreign Business Asset Exception

3. Extension of Assessment Period

VII. Treatment of Expatriated Entities Under § 7874

A. Background

B. Regulation


WORKING PAPERS

Working Papers

Table of Worksheets

Worksheet 1 House Ways & Means Committee Report on 1984 Tax Act H.R. Rep. 98-432 (Part 2), 98th Cong., 2d Sess. 1307-25 (1984)

Worksheet 2 Senate Finance Committee Report on 1984 Tax Act S. Prt. 98-169 (Vol. I), 98th Cong., 2d Sess. 352-70 (1984)

Worksheet 3 Conference Committee Report on 1984 Tax Act H.R. Rep. 98-861, 98th Cong., 2d Sess. 951-7 (1984)

Worksheet 4 Staff of the Joint Committee on Taxation General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984 JCS-41-84, 98th Cong., 2d Sess. 420-37 (1984)

Worksheet 5 Extract from Preamble to 1986 Temporary Regulations T.D. 8087, 1986-1 C.B. 175-7

Worksheet 6 Extract from Preamble to 1991 Proposed Regulations INTL-54-91 and INTL-178-86, 1991-2 C.B. 1070-2

Worksheet 7 Preamble to 12/95 Anti-Inversion Temporary Regulations T.D. 8638, 1996-1 C.B. 43

Worksheet 8 Preamble to 1996 Anti-Inversion Final Regulations, T.D. 8702

Worksheet 9 Preamble to 1998 Final Regulations for Outbound Stock Transfers T.D. 8770, 1998-27 I.R.B. 4

Worksheet 10 Preamble to 2005 Proposed Regulations for § 367 Aspects of § 368(a)(1)(A) Mergers or Consolidations Involving Foreign Corporations, REG-125628-01, 2005-7 I.R.B. 536

Worksheet 11 Preamble to 2005 Proposed Regulations for § 367 Aspects of Cross-Border § 304 Transactions, REG-127740-04, 2005-24 I.R.B. 1254

Worksheet 12 Preamble to 2006 Final and Temporary Regulations for § 367 Aspects of § 368(a)(1)(A) Mergers or Consolidations Involving Foreign Corporations, T.D. 9243, 2006-8 I.R.B. 475

Worksheet 13 Preamble to 2006 Final Regulations for § 367 Aspects of Cross-Border § 304 Transactions T.D. 9250, 2006-11 I.R.B. 588

Worksheet 14 Preamble to 2007 Final and Temporary Regulations for Post-GRA Asset Reorganizations and Other Transactions T.D. 9311, 2007-10 I.R.B. 635

Worksheet 15 Preamble to 2008 Proposed Regulations for § 367(a)(5) REG-209006-89, 2008-41 I.R.B. 867

Worksheet 16 Preamble to 2009 Final Regulations for Post-GRA Asset Reorganizations and Other Transactions T.D. 9446, 2009-9 I.R.B. 603

Worksheet 17 Flowchart of Section 367(a) Treatment of Outbound Transfers of Property

Worksheet 18 Form 926 - Return by a U.S. Transferor of Property to a Foreign Corporation

Worksheet 19 Form 8806 - Information Return for Acquisition of Control or Substantial Change in Capital Source

Bibliography

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IRS Guidance:

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