26 CFR §1.7874-5

1. (a)General rule. Stock of a foreign acquiring corporation that is described in section 7874(a)(2)(B)(ii) shall not cease to be so described as a result of any subsequent transfer of the stock by the former domestic entity shareholder or former domestic entity partner that received such stock, even if the subsequent transfer is related to the domestic entity acquisition.
2. (b)Example. The rule of this section is illustrated by the following example:
3. (c)Certain transfers involving expanded affiliated group members. For rules addressing whether certain stock is treated as held by members of the expanded affiliated group for purposes of applying section 7874(c)(2)(A) and § 1.7874-1, see § 1.7874-6.
4. (d)Definitions. The definitions provided in § 1.7874-12 apply for purposes of this section.
5. (e)Applicability dates. This section applies to domestic entity acquisitions that are completed on or after January 16, 2014.