Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction

Below is a chart of Rev. Rul. 67-192 in which the I.R.S. held that section 367 applied to a transaction where a U.S. corporation contributed assets with built-in gains and losses to a foreign corporation.  As a result, the built-in gains were recognized and the built-in losses were not. 

The chart can be viewed as a PDF file here: Rev. Rul. 67-192