80_FR_76440
Page Range | 76205-76206 | |
FR Document | 2015-30869 |
[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] ======================================================================= ----------------------------------------------------------------------- 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
Category | Regulatory Information | |
Collection | Federal Register | |
sudoc Class | AE 2.7: GS 4.107: AE 2.106: | |
Publisher | Office of the Federal Register, National Archives and Records Administration | |
Section | Rules and Regulations | |
Action | Correcting amendment. | |
Dates | This correction is effective December 8, 2015 and applicable September 21, 2015. | |
Contact | Douglas C. Bates at (202) 317-6065 (not a toll-free number). | |
FR Citation | 80 FR 76205 | |
RIN Number | 1545-BF51 and 1545-BM78 | |
CFR Associated | Income Taxes and Reporting and Recordkeeping Requirements |