§ 1.367(a)-6. Transfer of foreign branch with previously deducted losses.

Other regulations under § 367

• § 1.367(a)-0 Table of contents.
• § 1.367(a)-1 Transfers to foreign corporations subject to section 367(a): In general.
• § 1.367(a)-1T Transfers to foreign corporations subject to section 367(a): In general (temporary).
• § 1.367(a)-2 Exceptions for transfers of property for use in the active conduct of a trade or business.
• § 1.367(a)-3 Treatment of transfers of stock or securities to foreign corporations.
• § 1.367(a)-4 Special rule applicable to U.S. depreciated property.
• § 1.367(a)-6T Transfer of foreign branch with previously deducted losses (temporary).
• § 1.367(a)-7 Outbound transfers of property described in section 361(a) or (b).
• § 1.367(a)-8 Gain recognition agreement requirements.
• § 1.367(a)-9T Treatment of deemed section 351 exchanges pursuant to section 304(a)(1) (temporary).
• § 1.367(b)-0 Table of contents.
• § 1.367(b)-1 Other transfers.
• § 1.367(b)-2 Definitions and special rules.
• § 1.367(b)-3 Repatriation of foreign corporate assets in certain nonrecognition transactions.
• § 1.367(b)-3T Repatriation of foreign corporate assets in certain nonrecognition transactions (temporary).
• § 1.367(b)-4 Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions.
• § 1.367(b)-5 Distributions of stock described in section 355.
• § 1.367(b)-6 Effective/applicability dates and coordination rules.
• § 1.367(b)-7 Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.
• § 1.367(b)-9 Special rule for F reorganizations and similar transactions.
• § 1.367(b)-10 Acquisition of parent stock or securities for property in triangular reorganizations.
• § 1.367(b)-12 Subsequent treatment of amounts attributed or included in income.
• § 1.367(b)-13 Special rules for determining basis and holding period.
• § 1.367(d)-1 Transfers of intangible property to foreign corporations.
• § 1.367(d)-1T Transfers of intangible property to foreign corporations (temporary).
• § 1.367(e)-0 Outline of §§ 1.367(e)-1 and 1.367(e)-2.
• § 1.367(e)-1 Distributions described in section 367(e)(1).
• § 1.367(e)-2 Distributions described in section 367(e)(2).

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

• § 367 Foreign corporations

Regulations it cites

• § 1.367(a)-6T Transfer of foreign branch with previously deducted losses (temporary).
• § 1.367(a)-2 Exceptions for transfers of property for use in the active conduct of a trade or business.
• § 1.367(d)-1 Transfers of intangible property to foreign corporations.
• § 301.7701-3 Classification of certain business entities.

Cited by 7 other regulations

• § 1.367(a)-0 Table of contents.
• § 1.367(a)-1 Transfers to foreign corporations subject to section 367(a): In general.
• § 1.367(a)-3 Treatment of transfers of stock or securities to foreign corporations.
• § 1.367(a)-7 Outbound transfers of property described in section 361(a) or (b).
• § 1.367(d)-1 Transfers of intangible property to foreign corporations.
• § 1.1248-8 Earnings and profits attributable to stock following certain non-recognition transactions.
• § 1.6038B-1 Reporting of certain transfers to foreign corporations.

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

1. December 16, 2016Issued by T.D. 9803 (81 FR 91028)

Where it sits in 26 CFR

1. Subchapter A Income tax
2. Part 1 Income taxes
3. Effects on corporation

Nearby sections

• § 1.367(a)-1T Transfers to foreign corporations subject to section 367(a): In general (temporary).
• § 1.367(a)-2 Exceptions for transfers of property for use in the active conduct of a trade or business.
• § 1.367(a)-3 Treatment of transfers of stock or securities to foreign corporations.
• § 1.367(a)-4 Special rule applicable to U.S. depreciated property.
• § 1.367(a)-6 Transfer of foreign branch with previously deducted losses.
• § 1.367(a)-6T Transfer of foreign branch with previously deducted losses (temporary).
• § 1.367(a)-7 Outbound transfers of property described in section 361(a) or (b).
• § 1.367(a)-8 Gain recognition agreement requirements.
• § 1.367(a)-9T Treatment of deemed section 351 exchanges pursuant to section 304(a)(1) (temporary).