Par. 2. Section 1.367(b)-3 is amended by: 1. Revising the introductory text of paragraph (g)(2)(i); and 2. Adding a sentence to the end of paragraph (g)(7)(i). The revisions and addition read as follows:
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(g) * * *
(2) * * *
(i) Excess asset basis. The term excess asset basis means, with respect to a foreign acquired corporation, the amount (determined after the application of § 1.987-16(d)) by which the inside asset basis of that corporation exceeds the sum of the following amounts:
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(7) * * *
(i) * * * Paragraph (g)(2)(i) of this section, to the extent it relates to the application of § 1.987-16(d), applies to transactions completed within taxable years of the domestic acquiring corporation ending on or after [date of filing of final regulations with the Federal Register ].
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