Finalization of regs on gain from certain section 304 transfers of stock to foreign corporations

The Treasury/IRS has finalized regulations ((T.D. 9585), available now on BNA and to be published in the Federal Register on Apr. 24) under sections 367(a) and (b) dealing with transfers of stock to foreign corporations under section 304.  They treat resulting section 301(c)(3) gain on a distribution from a foreign corporation as gain from a sale or exchange for purposes of section 1248(a).