80_FR_76440 80 FR 76205 - Reorganizations Under Section 368(a)(1)(F); Section 367(a) and Certain Reorganizations Under Section 368(a)(1)(F); Correction

80 FR 76205 - Reorganizations Under Section 368(a)(1)(F); Section 367(a) and Certain Reorganizations Under Section 368(a)(1)(F); Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 80, Issue 235 (December 8, 2015)

Page Range76205-76206
FR Document2015-30869

This document contains corrections to final regulations (TD 9739) that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F), and which were published in the Federal Register on Monday, September 21, 2015 (80 FR 56904).

Federal Register, Volume 80 Issue 235 (Tuesday, December 8, 2015)
[Federal Register Volume 80, Number 235 (Tuesday, December 8, 2015)]
[Rules and Regulations]
[Pages 76205-76206]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-30869]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9739]
RIN 1545-BF51; 1545-BM78


Reorganizations Under Section 368(a)(1)(F); Section 367(a) and 
Certain Reorganizations Under Section 368(a)(1)(F); Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

-----------------------------------------------------------------------

SUMMARY: This document contains corrections to final regulations (TD 
9739) that provide guidance regarding the qualification of a 
transaction as a corporate reorganization under section 368(a)(1)(F), 
and which were published in the Federal Register on Monday, September 
21, 2015 (80 FR 56904).

DATES: This correction is effective December 8, 2015 and applicable 
September 21, 2015.

FOR FURTHER INFORMATION CONTACT: Douglas C. Bates at (202) 317-6065 
(not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9739) that are the subject of this 
correction are under section 367 and 368 of the Internal Revenue Code.

Need for Correction

    As published, the final regulation (TD 9739) contains 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 amended 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 1.368-2 is amended by revising the last sentence of 
paragraph (m)(4) Example 5. and revising the third sentence of Example 
7. to read as follows:


Sec.  1.368-2  Definition of terms.

* * * * *
    (m) * * *
    (4) * * *
    Example 5. * * * The result would be the same with respect to 
qualification under section 368(a)(1)(F) if, instead of merging into 
S2, S1 completely liquidates or is deemed to liquidate by reason of 
a conversion in an entity disregarded as separate from its owner 
under Sec.  301.7701-3 of this chapter.
* * * * *

[[Page 76206]]

    Example 7. * * * Each of T, P, and S is a State A corporation 
engaged in a manufacturing business.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-30869 Filed 12-7-15; 8:45 am]
BILLING CODE 4830-01-P



                                                             Federal Register / Vol. 80, No. 235 / Tuesday, December 8, 2015 / Rules and Regulations                                                          76205

                                              APPENDIX TO AD 2015–24–05—MODELS AFFECTED/MODEL SERIAL NUMBERS/APPLICABLE TEXT FOR SUPPLEMENTAL
                                                       PAGE TO PILOT’S OPERATING HANDBOOK (POH)/AIRPLANE FLIGHT MANUAL (AFM)—Continued
                                                                                                                                                                             Placard text for limitations section
                                                              Models affected                                             Model serial No.                                           of the POH/AFM

                                           PA–23–250 (six place) Aztec ‘‘C’’ PA–E23–250                27–2505 through 27–3836, 27–3838 through                      WARNING—UNCOORDINATED       MANEU-
                                            (six place) Aztec ‘‘C’’.                                     27–3943.                                                     VERS, INCLUDING SIDE SLIPS OF 30
                                                                                                                                                                      SECONDS OR MORE, FOR ANY REA-
                                                                                                                                                                      SON, AND FAST TAXI TURNS JUST
                                                                                                                                                                      PRIOR TO TAKEOFF CAN CAUSE LOSS
                                                                                                                                                                      OF POWER IF FUEL TANKS IN USE ARE
                                                                                                                                                                      LESS THAN 1⁄2 FULL.
                                           PA–23–250 (six place) Aztec ‘‘D’’ PA–E23–250                27–3837, 27–3944 through 27–4425, 27–                         WARNING—UNCOORDINATED       MANEU-
                                            (six place) Aztec ‘‘D’’.                                     4427 through 27–4573.                                        VERS, INCLUDING SIDE SLIPS OF 30
                                                                                                                                                                      SECONDS OR MORE, FOR ANY REA-
                                                                                                                                                                      SON, AND FAST TAXI TURNS JUST
                                                                                                                                                                      PRIOR TO TAKEOFF CAN CAUSE LOSS
                                                                                                                                                                      OF POWER IF FUEL TANKS IN USE ARE
                                                                                                                                                                      LESS THAN 1⁄2 FULL.
                                           PA–23–250 (six place) Aztec ‘‘E’’ PA–E23–250                27–4426, 27–4574 through 27–7405476 ........                  WARNING—UNCOORDINATED       MANEU-
                                            (six place) Aztec ‘‘E’’.                                                                                                  VERS, INCLUDING SIDE SLIPS OF 30
                                                                                                                                                                      SECONDS OR MORE, FOR ANY REA-
                                                                                                                                                                      SON, AND FAST TAXI TURNS JUST
                                                                                                                                                                      PRIOR TO TAKEOFF CAN CAUSE LOSS
                                                                                                                                                                      OF POWER IF FUEL TANKS IN USE ARE
                                                                                                                                                                      LESS THAN 1⁄2 FULL.
                                           PA–30 Twin Comanche .....................................   30–1 through 30–2000 .....................................    WARNING—UNCOORDINATED       MANEU-
                                                                                                                                                                      VERS, INCLUDING SIDE SLIPS OF 30
                                                                                                                                                                      SECONDS OR MORE, FOR ANY REA-
                                                                                                                                                                      SON, AND FAST TAXI TURNS JUST
                                                                                                                                                                      PRIOR TO TAKEOFF CAN CAUSE LOSS
                                                                                                                                                                      OF POWER IF FUEL TANKS IN USE ARE
                                                                                                                                                                      LESS THAN 1⁄4 FULL.
                                           PA–39 Twin Comanche .....................................   39–1 through 39–155 .......................................   WARNING—UNCOORDINATED       MANEU-
                                                                                                                                                                      VERS, INCLUDING SIDE SLIPS OF 30
                                                                                                                                                                      SECONDS OR MORE, FOR ANY REA-
                                                                                                                                                                      SON, AND FAST TAXI TURNS JUST
                                                                                                                                                                      PRIOR TO TAKEOFF CAN CAUSE LOSS
                                                                                                                                                                      OF POWER IF FUEL TANKS IN USE ARE
                                                                                                                                                                      LESS THAN 1⁄4 FULL.



                                             Issued in Kansas City, Missouri, on                       9739) that provide guidance regarding                         Correction of Publication
                                           November 24, 2015.                                          the qualification of a transaction as a                         Accordingly, 26 CFR part 1 is
                                           Pat Mullen,                                                 corporate reorganization under section                        amended by making the following
                                           Acting Manager, Small Airplane Directorate,                 368(a)(1)(F), and which were published                        correcting amendments:
                                           Aircraft Certification Service.                             in the Federal Register on Monday,
                                           [FR Doc. 2015–30633 Filed 12–7–15; 8:45 am]                 September 21, 2015 (80 FR 56904).                             PART 1—INCOME TAXES
                                           BILLING CODE 4910–13–P                                      DATES: This correction is effective
                                                                                                       December 8, 2015 and applicable                               ■ Paragraph 1. The authority citation
                                                                                                       September 21, 2015.                                           for part 1 continues to read in part as
                                                                                                       FOR FURTHER INFORMATION CONTACT:                              follows:
                                           DEPARTMENT OF THE TREASURY
                                                                                                       Douglas C. Bates at (202) 317–6065 (not                           Authority: 26 U.S.C. 7805 * * *
                                           Internal Revenue Service                                    a toll-free number).                                          ■ Par. 2. Section 1.368–2 is amended by
                                                                                                       SUPPLEMENTARY INFORMATION:                                    revising the last sentence of paragraph
                                           26 CFR Part 1                                                                                                             (m)(4) Example 5. and revising the third
                                                                                                       Background
                                           [TD 9739]                                                                                                                 sentence of Example 7. to read as
                                                                                                         The final regulations (TD 9739) that                        follows:
                                           RIN 1545–BF51; 1545–BM78                                    are the subject of this correction are
                                                                                                       under section 367 and 368 of the                              § 1.368–2    Definition of terms.
                                           Reorganizations Under Section                               Internal Revenue Code.                                        *       *    *       *     *
                                           368(a)(1)(F); Section 367(a) and Certain                    Need for Correction                                               (m) * * *
                                           Reorganizations Under Section                                                                                                 (4) * * *
                                           368(a)(1)(F); Correction                                      As published, the final regulation (TD                         Example 5. * * * The result would be the
                                                                                                       9739) contains errors that may prove to                       same with respect to qualification under
Lhorne on DSK9F6TC42PROD with RULES




                                           AGENCY:  Internal Revenue Service (IRS),                    be misleading and are in need of                              section 368(a)(1)(F) if, instead of merging into
                                           Treasury.                                                   clarification.                                                S2, S1 completely liquidates or is deemed to
                                           ACTION: Correcting amendment.                                                                                             liquidate by reason of a conversion in an
                                                                                                       List of Subjects in 26 CFR Part 1                             entity disregarded as separate from its owner
                                           SUMMARY:  This document contains                              Income taxes, Reporting and                                 under § 301.7701–3 of this chapter.
                                           corrections to final regulations (TD                        recordkeeping requirements.                                   *      *      *      *     *


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                                           76206             Federal Register / Vol. 80, No. 235 / Tuesday, December 8, 2015 / Rules and Regulations

                                             Example 7. * * * Each of T, P, and S is                DEPARTMENT OF HOMELAND                                other Federal, State, or local law
                                           a State A corporation engaged in a                       SECURITY                                              enforcement agencies in enforcing this
                                           manufacturing business.                                                                                        regulation.
                                           *      *      *       *      *                           Coast Guard                                             This document is issued under
                                                                                                                                                          authority of 33 CFR 100.701 and 5
                                           Martin V. Franks,                                        33 CFR Part 100                                       U.S.C. 552 (a).
                                           Chief, Publications and Regulations Branch,                                                                      The Coast Guard will provide notice
                                                                                                    [Docket No. USCG–2015–0783]
                                           Legal Processing Division, Associate Chief                                                                     of the regulated areas by Local Notice to
                                           Counsel (Procedure and Administration).                  Special Local Regulations; Recurring                  Mariners, Broadcast Notice to Mariners,
                                           [FR Doc. 2015–30869 Filed 12–7–15; 8:45 am]              Marine Events in the Seventh Coast                    and on-scene designated
                                           BILLING CODE 4830–01–P                                   Guard District                                        representatives.
                                                                                                                                                            Dated: November 10, 2015.
                                                                                                    AGENCY: Coast Guard, DHS.
                                                                                                                                                          G.L. Tomasulo,
                                                                                                    ACTION: Notice of enforcement.
                                                                                                                                                          Captain, U.S. Coast Guard, Captain of the
                                           DEPARTMENT OF DEFENSE                                    SUMMARY:    The Coast Guard will enforce              Port Charleston.
                                                                                                    the regulation pertaining to the                      [FR Doc. 2015–30908 Filed 12–7–15; 8:45 am]
                                           Office of the Secretary
                                                                                                    Charleston Parade of Boats from 4:00                  BILLING CODE 9110–04–P
                                                                                                    p.m. through 8:00 p.m. on December 12,
                                           32 CFR Part 88
                                                                                                    2015. This action is necessary to ensure
                                                                                                    safety of life on navigable waters of the             DEPARTMENT OF HOMELAND
                                           [Docket ID: DOD–2013–OS–0236]                            United States during the Charleston                   SECURITY
                                                                                                    Parade of Boats. During the enforcement
                                                                                                                                                          Coast Guard
                                           RIN 0790–AJ17                                            period, the special local regulation
                                                                                                    establishes a regulated area which will
                                           Transition Assistance Program (TAP)                                                                            33 CFR Part 165
                                                                                                    prohibit all people and vessels from
                                           for Military Personnel; Correction                       entering. Vessels may enter, transit                  [Docket Number USCG–2014–1044]
                                                                                                    through, anchor in, or remain within the              RIN 1625–AA00
                                           AGENCY: Under Secretary of Defense for                   area if authorized by the Captain of the
                                           Personnel and Readiness, DoD.                            Port Charleston or a designated                       Safety Zone; Shore (Belt) Parkway
                                           ACTION:    Interim final rule; correction.               representative.                                       Bridge Construction, Mill Basin;
                                                                                                    DATES: The Charleston Parade of Boats                 Brooklyn, NY
                                           SUMMARY:   On Monday, November 30,                       regulation in 33 CFR 100.701 will be                  AGENCY:    Coast Guard, DHS.
                                           2015 (80 FR 74678–74694), the                            enforced from 4:00 p.m. through 8:00                  ACTION:   Final rule.
                                           Department of Defense published an                       p.m. December 12, 2015.
                                           interim final rule titled Transition                     FOR FURTHER INFORMATION CONTACT: If                   SUMMARY:   The Coast Guard is
                                           Assistance Program (TAP) for Military                    you have questions on this rule, call or              establishing a safety zone on the
                                           Personnel. Subsequent to the                             email LT John Downing, Sector                         navigable waters of Mill Basin
                                           publication of the interim final rule, the               Charleston Office of Waterways                        surrounding the Shore (Belt) Parkway
                                           Department of Defense discovered that                    Management, Coast Guard; telephone                    Bridge. This rule allows the Coast Guard
                                                                                                    843–740–3184, email John.Z.Downing@                   to prohibit all vessel traffic through the
                                           the phone number in the FOR FURTHER
                                                                                                    uscg.mil.                                             safety zone during bridge replacement
                                           INFORMATION CONTACT section was not
                                                                                                    SUPPLEMENTARY INFORMATION: The Coast
                                                                                                                                                          operations, both planned and
                                           correct.                                                                                                       unforeseen, that could pose an
                                                                                                    Guard will enforce the special local
                                                This correction is effective on
                                           DATES:                                                   regulation for the Charleston Parade of               imminent hazard to persons and vessels
                                           December 8, 2015.                                        Boats in 33 CFR 100.701 Table 1 from                  operating in the area. This rule is
                                                                                                    4:00 p.m. through 8:00 p.m. on                        necessary to provide for the safety of life
                                           FOR FURTHER INFORMATION CONTACT:                Ron                                                            in the vicinity of the construction of the
                                                                                                    December 12, 2015.
                                           Horne, 703–614–8631.                                                                                           new Shore (Belt) Parkway Bridge and
                                                                                                       Under the provisions of 33 CFR
                                           SUPPLEMENTARY INFORMATION:     On page                   100.701 no vessels or people may enter                demolition of the old Shore (Belt)
                                           74679, in the first column, the FOR                      the regulated area, unless it receives                Parkway Bridge.
                                           FURTHER INFORMATION CONTACT section is                   permission to do so from the Captain of               DATES: This rule is effective January 7,
                                           revised to correct the phone number to                   the Port. Only event sponsors,                        2016.
                                           read as set forth above.                                 designated participants, and official                 ADDRESSES: To view documents
                                                                                                    patrol vessels are allowed to enter the               mentioned in this preamble as being
                                             Dated: December 2, 2015.                                                                                     available in the docket, go to http://
                                                                                                    regulated area. This rule creates a
                                           Aaron Siegel,                                            regulated area that will encompass a                  www.regulations.gov, type USCG–2014–
                                           Alternate OSD Federal Register Liaison                   portion of the waterways during the                   1044 in the ‘‘SEARCH’’ box and click
                                           Officer, Department of Defense.                          parade transit from Charleston Harbor                 ‘‘SEARCH.’’ Click on Open Docket
                                           [FR Doc. 2015–30839 Filed 12–7–15; 8:45 am]              Anchorage A through Bennis Reach,                     Folder on the line associated with this
                                           BILLING CODE 5001–06–P                                   Horse Reach, Hog Island Reach, Town                   rule.
                                                                                                    Creek Lower Reach, Ashley River, and                  FOR FURTHER INFORMATION CONTACT: If
Lhorne on DSK9F6TC42PROD with RULES




                                                                                                    finishing at City Marina. Spectator                   you have questions on this rule, call or
                                                                                                    vessels may transit outside the regulated             email Mr. Jeff Yunker, Coast Guard
                                                                                                    area, but may not anchor, block, loiter               Sector New York Waterways
                                                                                                    in, or impede the transit of parade                   Management Division, U.S. Coast Guard
                                                                                                    participants or official patrol vessels.              718–354–4195, email Jeff.M.Yunker@
                                                                                                    The Coast Guard may be assisted by                    uscg.mil.


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Document Created: 2015-12-14 13:27:05
Document Modified: 2015-12-14 13:27:05
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 amendment.
DatesThis correction is effective December 8, 2015 and applicable September 21, 2015.
ContactDouglas C. Bates at (202) 317-6065 (not a toll-free number).
FR Citation80 FR 76205 
RIN Number1545-BF51 and 1545-BM78
CFR AssociatedIncome Taxes and Reporting and Recordkeeping Requirements

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