SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (the “Treasury Department”) and the Internal Revenue

January 29, 2024 622 Bulletin No. 2024–5

Service (the “IRS”) intend to issue proposed regulations addressing the treatment of basis provided under section 961(c) in certain transactions in which a domestic corporation acquires stock of a controlled foreign corporation (as defined in section 957(a), a “CFC”) in a liquidation described in section 332 or an asset reorganization described in section 368(a) (1). ¹ Section 2 of this notice provides background on section 961 and other relevant Code provisions. Section 3 of this notice describes the regulations that the Treasury Department and the IRS intend to issue. Section 4 of this notice permits taxpayers to rely on the rules described in section 3 of this notice. Section 5 of this notice requests comments and provides contact information.