Layla Asali discussed current IRS guidance projects during a conference sponsored by the American Bar Association Section of Taxation in Philadelphia on November 14. Representatives from the Internal Revenue Service (IRS) Office of Associate Chief Counsel (International) provided a new 2024 timeline for proposed PTEP regulations, adding that the IRS was "on the homestretch" of the regs' release, and discussed the motivations behind recently proposed regulations (REG-117614-14) on section 367(b) related to triangular reorganizations and inbound nonrecognition transactions.