New proposed GRA regulations: Failures to file and deficiencies in GRAs and other documents

January 2013


US persons who either fail to timely file a gain recognition agreement (GRA) or related documents, or file such documents with material deficiencies, will face different rules for obtaining relief under proposed regulations released on January 30, 2013. The proposed regulations also address failures to file (and deficient filings of) certain documents concerning outbound transfers, as well as Form 926, and the regulations for liquidations into foreign corporations.

This newsalert describes the notable differences between the current regulations and the proposed regulations as well as actions that may be considered by taxpayers that have previously transferred or plan to transfer stock or securities to a foreign corporation.

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Doug McHoney
Co-leader, US Integrated Global Structuring team
Tel: +1 (312) 298 2527

Calum Dewar
Co-leader, US Integrated Global Structuring team
Tel: +1 (646) 471 5254

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