80_FR_39070 80 FR 38940 - Partnership Transactions Involving Equity Interests of a Partner; Correction

80 FR 38940 - Partnership Transactions Involving Equity Interests of a Partner; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 80, Issue 130 (July 8, 2015)

Page Range38940-38941
FR Document2015-16674

This document contains corrections to final and temporary regulations (TD 9722) that were published in the Federal Register on June 12, 2015 (80 FR 33402). The final and temporary regulations prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner.

Federal Register, Volume 80 Issue 130 (Wednesday, July 8, 2015) 
[Federal Register Volume 80, Number 130 (Wednesday, July 8, 2015)]
[Rules and Regulations]
[Pages 38940-38941]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-16674]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9722]
RIN 1545-BM35


Partnership Transactions Involving Equity Interests of a Partner; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9722) that were published in the Federal Register on 
June 12, 2015 (80 FR 33402). The final and temporary regulations 
prevent a corporate partner from avoiding corporate-level gain through 
transactions with a partnership involving equity interests of the 
partner.

DATES: This correction is effective on July 2, 2015 and applicable 
beginning June 12, 2015.

FOR FURTHER INFORMATION CONTACT: Kevin I. Babitz at (202) 317-6852 (not 
a toll free number).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations (TD 9722) that are the subject 
of this correction are under sections 311(b), 336(a), and 337(d) of the 
Internal Revenue Code.

Need for Correction

    As published, the final and temporary regulations (TD 9722) contain 
errors that may prove to be misleading and are in need of 
clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority:  26 U.S.C. 7805 * * *


0
Par. 2. Section 1.337(d)-3T is amended by revising paragraphs (c)(2)(i) 
and (f)(2)(ii) to read as follows:

[[Page 38941]]

Sec.  1.337(d)-3T  Gain recognition upon certain partnership 
transactions involving a partner's stock (temporary).

* * * * *
    (c) * * *
    (2) * * * (i) In general. With respect to a Corporate Partner, 
Stock of the Corporate Partner includes the Corporate Partner's stock, 
or other equity interests, including options, warrants, and similar 
interests, in the Corporate Partner or a corporation that controls the 
Corporate Partner within the meaning of section 304(c), except that 
section 318(a)(1) and (3) shall not apply. Stock of the Corporate 
Partner also includes interests in any entity to the extent that the 
value of the interest is attributable to Stock of the Corporate 
Partner.
    (f) * * *
    (2) * * *
    (ii) Is not distributed to the Corporate Partner or a corporation 
that controls the Corporate Partner within the meaning of section 
304(c), except that section 318(a)(1) and (3) shall not apply.
* * * * *


Sec.  1.732-1T  [Amended]

0
Par 3. Section 1.732-1T paragraph (c)(5)(ii) is amended by removing the 
word ``Nothwithstanding'' and adding in its place the word 
``Notwithstanding''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-16674 Filed 7-2-15; 4:15 pm]
 BILLING CODE 4830-01-P

38940 Federal Register / Vol. 80, No. 130 / Wednesday, July 8, 2015 / Rules and Regulations shortage. This biological product for not notifying FDA as required under DEPARTMENT OF THE TREASURY shortages list will include the following paragraph (a) of this section. information: Internal Revenue Service (f) Definitions. The following (i) The names and National Drug definitions of terms apply to this Codes for such biological products, or 26 CFR Part 1 the alternative standards for section: identification and labeling that have Biological product shortage or [TD 9722] been recognized as acceptable by the shortage means a period of time when Center Director; the demand or projected demand for the (ii) The name of each applicant for RIN 1545–BM35 biological product within the United such biological products; States exceeds the supply of the Partnership Transactions Involving (iii) The reason for the shortage, as biological product. Equity Interests of a Partner; determined by FDA, selecting from the Intended for use in the prevention or Correction following categories: Requirements related to complying with good treatment of a debilitating disease or AGENCY: Internal Revenue Service (IRS), manufacturing practices; regulatory condition means a biological product Treasury. delay; shortage of an active ingredient; intended for use in the prevention or treatment of a disease or condition ACTION: Correcting amendments. shortage of an inactive ingredient component; discontinuation of the associated with mortality or morbidity SUMMARY: This document contains manufacture of the biological product; that has a substantial impact on day-to- corrections to final and temporary delay in shipping of the biological day functioning. regulations (TD 9722) that were product; demand increase for the Life supporting or life sustaining published in the Federal Register on biological product; or other reason; and means a biological product that is June 12, 2015 (80 FR 33402). The final (iv) The estimated duration of the essential to, or that yields information and temporary regulations prevent a shortage. corporate partner from avoiding (2) Confidentiality. FDA may choose that is essential to, the restoration or continuation of a bodily function corporate-level gain through not to make information collected to important to the continuation of human transactions with a partnership implement this paragraph available on life. involving equity interests of the partner. the biological product shortages list or available under section 506C(c) of the Meaningful disruption means a DATES: This correction is effective on Federal Food, Drug, and Cosmetic Act change in production that is reasonably July 2, 2015 and applicable beginning (21 U.S.C. 356c(c)) if FDA determines likely to lead to a reduction in the June 12, 2015. that disclosure of such information supply of a biological product by a FOR FURTHER INFORMATION CONTACT: would adversely affect the public health manufacturer that is more than Kevin I. Babitz at (202) 317–6852 (not a (such as by increasing the possibility of negligible and affects the ability of the toll free number). hoarding or other disruption of the manufacturer to fill orders or meet SUPPLEMENTARY INFORMATION: availability of the biological product to expected demand for its product, and patients). FDA will also not provide Background does not include interruptions in information on the public shortages list manufacturing due to matters such as The final and temporary regulations or under section 506C(c) of the Federal routine maintenance or insignificant (TD 9722) that are the subject of this Food, Drug, and Cosmetic Act that is changes in manufacturing so long as the correction are under sections 311(b), protected by 18 U.S.C. 1905 or 5 U.S.C. 336(a), and 337(d) of the Internal manufacturer expects to resume 552(b)(4), including trade secrets and Revenue Code. operations in a short period of time. commercial or financial information that is considered confidential or Significant disruption means a change Need for Correction privileged under § 20.61 of this chapter. in production that is reasonably likely As published, the final and temporary (e) Noncompliance letters. If an to lead to a reduction in the supply of regulations (TD 9722) contain errors that applicant fails to submit a notification blood or blood components by a may prove to be misleading and are in as required under paragraph (a) of this manufacturer that substantially affects need of clarification. section and in accordance with the ability of the manufacturer to fill paragraph (b) of this section, FDA will orders or meet expected demand for its List of Subjects in 26 CFR Part 1 issue a letter to the applicant informing product, and does not include Income taxes, Reporting and it of such failure. interruptions in manufacturing due to recordkeeping requirements. (1) Not later than 30 calendar days matters such as routine maintenance or after the issuance of such a letter, the Correction of Publication insignificant changes in manufacturing applicant must submit to FDA a written Accordingly, 26 CFR part 1 is so long as the manufacturer expects to response setting forth the basis for corrected by making the following resume operations in a short period of noncompliance and providing the correcting amendments: time. required notification under paragraph (a) of this section and including the Dated: July 1, 2015. PART 1—INCOME TAXES information required under paragraph Leslie Kux, (c) of this section; and Associate Commissioner for Policy. ■ Paragraph 1. The authority citation (2) Not later than 45 calendar days for part 1 continues to read in part as tkelley on DSK3SPTVN1PROD with RULES [FR Doc. 2015–16659 Filed 7–7–15; 8:45 am] after the issuance of a letter under this follows: BILLING CODE 4164–01–P paragraph, FDA will make the letter and Authority: 26 U.S.C. 7805 * * * the applicant’s response to the letter public, unless, after review of the ■ Par. 2. Section 1.337(d)–3T is applicant’s response, FDA determines amended by revising paragraphs (c)(2)(i) that the applicant had a reasonable basis and (f)(2)(ii) to read as follows: VerDate Sep<11>2014 18:08 Jul 07, 2015 Jkt 235001 PO 00000 Frm 00028 Fmt 4700 Sfmt 4700 E:\FR\FM\08JYR1.SGM 08JYR1

Federal Register / Vol. 80, No. 130 / Wednesday, July 8, 2015 / Rules and Regulations 38941 § 1.337(d)–3T Gain recognition upon SUMMARY: This document contains DEPARTMENT OF HOMELAND certain partnership transactions involving a corrections to final and temporary SECURITY partner’s stock (temporary). regulations (TD 9722) that were * * * * * published in the Federal Register on Coast Guard (c) * * * June 12, 2015 (80 FR 33402). The final (2) * * * (i) In general. With respect and temporary regulations prevent a 33 CFR Part 165 to a Corporate Partner, Stock of the corporate partner from avoiding Corporate Partner includes the corporate-level gain through [Docket No. USCG–2015–0527] Corporate Partner’s stock, or other transactions with a partnership equity interests, including options, involving equity interests of the partner. Safety Zones; Recurring Events in warrants, and similar interests, in the DATES: This correction is effective on Captain of the Port Boston Zone Corporate Partner or a corporation that July 2, 2015 and applicable beginning controls the Corporate Partner within June 12, 2015. AGENCY: Coast Guard, DHS. the meaning of section 304(c), except FOR FURTHER INFORMATION CONTACT: that section 318(a)(1) and (3) shall not Kevin I. Babitz at (202) 317–6852 (not a ACTION: Notice of enforcement of apply. Stock of the Corporate Partner toll free number). regulation. also includes interests in any entity to SUPPLEMENTARY INFORMATION: the extent that the value of the interest SUMMARY: The Coast Guard will enforce is attributable to Stock of the Corporate Background the safety zones in the Captain of the Partner. The final and temporary regulations Port Boston Zone on the specified dates (f) * * * (TD 9722) that are the subject of this and times listed below. This action is (2) * * * correction are under sections 311(b), necessary to ensure the protection of the (ii) Is not distributed to the Corporate 336(a), and 337(d) of the Internal maritime public and event participants Partner or a corporation that controls Revenue Code. from the hazards associated with these the Corporate Partner within the annual recurring events. Under the meaning of section 304(c), except that Need for Correction provisions of our regulations, no person section 318(a)(1) and (3) shall not apply. As published, the final and temporary or vessel, except for the safety vessels * * * * * regulations (TD 9722) contain errors that assisting with the event may enter the may prove to be misleading and are in § 1.732–1T [Amended] need of clarification. safety zones unless given permission from the COTP or the designated on- ■ Par 3. Section 1.732–1T paragraph Correction of Publication scene representative. The Coast Guard (c)(5)(ii) is amended by removing the may be assisted by other Federal, State, Accordingly, the final regulations (TD word ‘‘Nothwithstanding’’ and adding 9722), that are the subject of FR Doc. or local law enforcement agencies in in its place the word 2015–14405, are corrected as follows: enforcing this regulation. ‘‘Notwithstanding’’. 1. On page 33404, in the preamble, the first column, the tenth and eleventh DATES: The regulation for the safety Martin V. Franks, lines from the top of the column, the zones described in 33 CFR 165.118 will Chief, Publications and Regulations Branch, language ‘‘that controls (within the be enforced on July 3, 2015 between Legal Processing Division, Associate Chief Counsel (Procedure and Administration). meaning of section 304(c)) the Corporate 7:00 p.m. to 11:00 p.m., on July 4, 2015 [FR Doc. 2015–16674 Filed 7–2–15; 4:15 pm] Partner.’’ is corrected to read ‘‘that from 9:00 p.m. to 11:00 p.m., on July 10, controls the Corporate Partner within 2015 from 6:00 a.m. to 4:00 p.m., and on BILLING CODE 4830–01–P the meaning of section 304(c), except July 11, 2015 from 8:30 a.m. to 10:30 that section 318(a)(1) and (3) shall not a.m., as listed in the table located in the DEPARTMENT OF THE TREASURY apply (section 304(c) control).’’. Supplementary Information. 2. On page 33404, in the preamble, the first column, the eighteenth through FOR FURTHER INFORMATION CONTACT: If Internal Revenue Service the twentieth line from the top of the you have questions on this document, 26 CFR Part 1 first full paragraph, the language ‘‘that call or email Mr. Mark Cutter, Coast controls the Corporate Partner within Guard Sector Boston Waterways [TD 9722] the meaning of section 304(c) (section Management Division, telephone 617– 304(c) control), whereas the’’ is 223–4000, email Mark.E.Cutter@ RIN 1545–BM35 corrected to read ‘‘that possesses section uscg.mil. Partnership Transactions Involving 304(c) control of the Corporate Partner, whereas the’’. SUPPLEMENTARY INFORMATION: The Coast Equity Interests of a Partner; Guard will enforce the safety zones Correction Martin V. Franks, listed in 33 CFR 165.118 on the AGENCY: Internal Revenue Service (IRS), Chief, Publications and Regulations Branch, specified dates and times as indicated in Treasury. Legal Processing Division, Associate Chief Table 1 below. Counsel (Procedure and Administration). ACTION: Final and temporary [FR Doc. 2015–16673 Filed 7–2–15; 4:15 pm] regulations; correction. BILLING CODE 4830–01–P TABLE 1 tkelley on DSK3SPTVN1PROD with RULES 7.1 City of Lynn 4th of July Celebration Fireworks ............................... • Event Type: Firework Display. • Sponsor: City of Lynn. • Date: July 3, 2015. • Time: 7:00 p.m. to 11:00 p.m. VerDate Sep<11>2014 18:08 Jul 07, 2015 Jkt 235001 PO 00000 Frm 00029 Fmt 4700 Sfmt 4700 E:\FR\FM\08JYR1.SGM 08JYR1


Document Created: 2018-02-23 09:12:51
Document Modified: 2018-02-23 09:12:51
CategoryRegulatory Information
CollectionFederal Register
sudoc ClassAE 2.7:
GS 4.107:
AE 2.106:
PublisherOffice of the Federal Register, National Archives and Records Administration
SectionRules and Regulations
ActionCorrecting amendments.
DatesThis correction is effective on July 2, 2015 and applicable beginning June 12, 2015.
ContactKevin I. Babitz at (202) 317-6852 (not a toll free number).
FR Citation80 FR 38940 
RIN Number1545-BM35
CFR AssociatedIncome Taxes and Reporting and Recordkeeping Requirements
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