Bulletin No. 2008-3 January 22, 2008

existing section 1.6039–1, with respect to such stock transfers.

Notice 2008–9, page 277. Section 1502. This notice provides that final regulations under section 1.1502–36 will not apply to a transfer to an unrelated person if the transfer is pursuant to an agreement that is binding before the date the regulations are published and at all times thereafter.

Notice 2008–10, page 277. This notice announces the intention to issue regulations under section 367(a) of the Code to clarify that certain outbound reorganizations that effectively repatriate earnings of foreign corporations to U.S. corporations will be subject to recognition of gain under section 367(a)(1).