Notice 2024-16 Announces Limited Guidance Under Section 961(c)

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the treatment of notional basis adjustments under section 961(c)[1] when all of the stock of a lower-tier “controlled foreign corporation” within the meaning of section 957(a) (“CFC”) is transferred by a CFC to a U.S. acquiring corporation in a section 332 liquidation or certain asset reorganizations described in section 368(a)(1).