Today, the IRS issued its final regulations on the coordination rule for indirect stock transfers under sections 367, 1248, and 6038B.  These regulations finalize the elimination of an exception to the coordination rule for certain outbound asset reorganizations, modify the exception for section 351 exchanges, modify the procedure for obtaining relief from failure to meet certain reporting requirements, and finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange.