Today, the IRS withdrew portions of regulations proposed in 2009 (REG-147636-08) and 2014 (REG-121534-12) with the issuance of REG-135734-14.  The withdrawn regulations issued in 2009 apply section 367 to cross-border stock transfers governed under section 304.  The withdrawn regulations from 2014 relate to certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation under section 7874.  These regulations have been withdrawn because the IRS says they do not reflect current law as announced by subsequently issued guidance.