Bulletin No. 2016–15 April 11, 2016

assets transferred in an outbound reorganization before the indirect stock transfer rules. The modifications finalize changes to the exceptions to the coordination rule by providing that under certain conditions – section 367(a) and (d) will not apply to the transferred assets to the extent those assets are retransferred to a domestic corporation. Second, these regulations finalize rules governing transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. Finally, these regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements.