Several years ago, the Service published Temp. Reg. 1.1502-13T along with Proposed Regulations which addressed the tax consequences with respect to intercompany gains of subsidiary stock that was part of a consolidated group of corporations
The U.S. Department of the Treasury having announced on June 2, 2011 that it planned to begin formal negotiation of amendments to the existing bilateral income tax treaty with Japan, which Treaty was entered into force in 2004, commenced negotiations on June 8-10 in Washington, D.C.
On March 4, 2011, the Treasury issued T.D.9515, containing final regulations on the treatment of certain intercompany gains with respect to stock owned by members of a consolidated group.