SECTION 1. OVERVIEW

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue regulations under section 367 of the Internal Revenue Code (Code) to modify the rules relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations, and the consequences to persons that receive parent stock or securities pursuant to such triangular reorganizations. This notice also announces that the Treasury Department and the IRS intend to issue regulations under section 367 to modify the amount of an income inclusion required in certain inbound nonrecognition transactions.