TITLE 26. INTERNAL REVENUE CODE § 367. Foreign corporations., 26 USCS § 367

Summary

(a) Transfers of property from the United States.

(1) General rule. If, in connection with any exchange described in section 332, 351, 354, 356, or 361 [26 USCS § 332, 351, 354, 356, or 361], a United States person transfers property to a foreign corporation, such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a corporation.

(2) Exception for certain stock or securities. Except to the extent provided in regulations, paragraph (1) shall not apply to the transfer of stock or securities of a foreign corporation which is a party to the exchange or a party to the reorganization.

(3) Special rule for transfer of partnership interests. Except as provided in regulations prescribed by the Secretary, a transfer by a United States person of an interest in a partnership to a foreign corporation in an exchange described in paragraph (1) shall, for purposes of this subsection, be treated as a transfer to such ...