This document contains temporary regulations under section 7874 of the Internal Revenue Code (Code) relating to the disregard of certain affiliateowned stock in determining whether a corporation is a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of the temporary regulations also serves as the text of the proposed

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the disregard of affiliateowned stock in determining the percentage of stock of a foreign corporation held by former shareholders or partners of a domestic entity, in order to determine whether the foreign corporation is

DEPARTMENT OF THE TREASURY : Internal Revenue Service