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The income tax regulations under section 367 will be amended to reflect the legislative changes made to that section, including changes in the Tax Cuts and Jobs Act (TCJA).  Section 367 provides generally that a foreign corporation will not be considered to be a corporation, for purposes of certain nonrecognition provisions of the Internal Revenue Code, upon the transfer of property to such corporation by a U.S. person.  TCJA amended section 367 by removing the active trade or business exception, for example, in section 367(a).  Accordingly, updates to the regulations under section 367(a), as well as other updates, are necessary.  Specifically, the regulations will provide guidance concerning the applicability of the general rule and its exceptions and special rules, including guidance concerning transfers of assets for use in the active conduct of a trade or business, stock transfers, transfers of intangible assets, and transfers of branch operations that have operated at a loss.