81_FR_17142 81 FR 17083 - Tax Treatment of Cafeteria Plans

81 FR 17083 - Tax Treatment of Cafeteria Plans

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 59 (March 28, 2016)

Page Range17083-17083
FR Document2016-07018

Federal Register, Volume 81 Issue 59 (Monday, March 28, 2016) 
[Federal Register Volume 81, Number 59 (Monday, March 28, 2016)]
[Rules and Regulations]
[Page 17083]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-07018]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1


Tax Treatment of Cafeteria Plans

CFR Correction

    In Title 26 of the Code of Federal Regulations, Part 1 (Sec. Sec.  
1.61 to 1.139), revised as of April 1, 2015, on page 545, Sec.  1.125-
4T is removed.

[FR Doc. 2016-07018 Filed 3-25-16; 8:45 am]
 BILLING CODE 1505-01-D

Federal Register / Vol. 81, No. 59 / Monday, March 28, 2016 / Rules and Regulations 17083 immediately after the transaction. (b) * * * § 1.1367–1 Adjustments to basis of Accordingly, Asset 2 is also loss duplication (3) The value and basis of all the stock shareholder’s stock in an S corporation. property. But for section 362(e)(2) and this or securities of the target corporation * * * * * section, DC’s basis in Asset 3 would be $32, held by the significant holder that is (c) * * * which would not exceed Asset 3’s $40 value immediately after the transaction. transferred in the transaction and such (2) Noncapital, nondeductible Accordingly, Asset 3 is not loss duplication holder’s basis in that stock or securities, expenses. * * * For basis adjustments property. determined immediately before the necessary to coordinate sections 1367 (iii) Basis in loss duplication property. DC’s transfer and aggregated as follows— and 362(e)(2), see § 1.362–4(e)(2). basis in Asset 1 is $56, computed as its $80 (i) Stock and securities with respect to * * * * * basis under section 362(a) reduced by $24, its which an election is made under section allocable portion of FC1’s $32 net built-in 362(e)(2)(C); and John M Dalrymple, loss ($30/40 × $32). DC’s basis in Asset 2 is (ii) Stock and securities not described Deputy Commissioner for Services and $112, computed as its $120 basis under in paragraph (b)(3)(i) of this section. Enforcement. section 362(a) reduced by $8, its allocable * * * * * Approved: February 16, 2016. portion of FC1’s $40 net built-in loss ($10/ $40 × $32). (e) Effective/applicability date. * * * Mark J. Mazur, (iv) Basis in other property. Under section Paragraphs (a)(3) and (b)(3) of this Assistant Secretary of the Treasury (Tax 358(a), FC1 has an exchanged basis of $232 section apply with respect to Policy). in the DC stock it receives in the transaction. reorganizations occurring on or after [FR Doc. 2016–06227 Filed 3–25–16; 8:45 am] (2) Application of section to FC2. FC2’s March 28, 2016, and also with respect BILLING CODE 4830–01–P transfer of Asset 3 is not a loss duplication to reorganizations occurring before such transaction because Asset 3’s value exceeds its basis immediately after the transaction. date as a result of an entity classification Accordingly, under section 362(a), DC’s basis election under § 301.7701–3 of this DEPARTMENT OF THE TREASURY in Asset 3 is $100. chapter filed on or after March 28, 2016, * * * * * unless such reorganization is pursuant Internal Revenue Service (j) Effective/applicability date. * * * to a binding agreement that was in effect The introductory text and Example 11 prior to March 28, 2016 and at all times 26 CFR Part 1 of paragraph (h) of this section apply thereafter. ■ Par. 13. Section 1.705–1 is amended Tax Treatment of Cafeteria Plans with respect to transactions occurring on or after March 28, 2016, and also by revising paragraph (a)(9) to read as CFR Correction with respect to transactions occurring follows: In Title 26 of the Code of Federal before such date as a result of an entity § 1.705–1 Determination of basis of Regulations, Part 1 (§§ 1.61 to 1.139), classification election under partner’s interest. revised as of April 1, 2015, on page 545, § 301.7701–3 of this chapter filed on or (a) * * * § 1.125–4T is removed. after March 28, 2016, unless such (9) For basis adjustments necessary to transaction is pursuant to a binding [FR Doc. 2016–07018 Filed 3–25–16; 8:45 am] coordinate sections 705 and 362(e)(2), agreement that was in effect prior to see § 1.362–4(e)(1). BILLING CODE 1505–01–D March 28, 2016 and at all times * * * * * thereafter. In addition, taxpayers may apply such provisions to any transaction ■ Par. 14. Section 1.755–1 is amended DEPARTMENT OF HOMELAND occurring after October 22, 2004. by adding a sentence after the second SECURITY ■ Par. 12. Section 1.368–3 is amended sentence of paragraph (b)(1)(i) to read as by revising paragraphs (a)(3) and (b)(3) follows: Coast Guard and adding a sentence to the end of § 1.755–1 Rules for allocation of basis. paragraph (e) to read as follows: 33 CFR Part 165 * * * * * (b) * * * [Docket No. USCG–2015–0530] § 1.368–3 Records to be kept and information to be filed with returns. (1) * * * (i) Application. * * * For transfers Safety Zones; Annual Events (a) * * * Requiring Safety Zones in the Captain (3) The value and basis of the assets, subject to section 334(b)(1)(B), see § 1.334–1(b)(3)(iii)(C)(1) (treating a of the Port Lake Michigan Zone— stock or securities of the target Michigan City Summerfest Fireworks, corporation transferred in the determination of basis under § 1.334– 1(b)(3) as a determination not by Lake Michigan transaction, determined immediately before the transfer and aggregated as reference to the transferor’s basis solely AGENCY: Coast Guard, DHS. follows— for purposes of applying section 755); for transfers subject to section 362(e)(1), ACTION: Notice of enforcement of (i) Importation property transferred in regulation. a loss importation transaction, as see § 1.362–3(b)(4)(i) (treating a defined in § 1.362–3(c)(2) and (3), determination of basis under § 1.362–3 SUMMARY: The Coast Guard will enforce respectively; as a determination not by reference to the Michigan City Summerfest (ii) Loss duplication property as the transferor’s basis solely for purposes Fireworks Safety Zone on a portion of defined in § 1.362–4(g)(1); of applying section 755); for transfers Lake Michigan on July 4, 2016. This (iii) Property with respect to which subject to section 362(e)(2), see § 1.362– action is necessary and intended to any gain or loss was recognized on the 4(c)(3)(i) (treating a determination of ensure safety of life and property on transfer (without regard to whether such basis under § 1.362–4 as a determination navigable waters prior to, during, and Lhorne on DSK5TPTVN1PROD with RULES property is also identified in paragraph by reference to the transferor’s basis for immediately after the fireworks display. (a)(3)(i) or (ii) of this section); all purposes). * * * During the enforcement period listed (iv) Property not described in * * * * * below, the Coast Guard will enforce paragraph (a)(3)(i), (ii), or (iii) of this ■ Par. 15. Section 1.1367–1 is amended restrictions upon, and control section; and by revising the last sentence of movement of, vessels in the safety zone. * * * * * paragraph (c)(2) to read as follows: No person or vessel may enter, transit, VerDate Sep<11>2014 14:39 Mar 25, 2016 Jkt 238001 PO 00000 Frm 00023 Fmt 4700 Sfmt 4700 E:\FR\FM\28MRR1.SGM 28MRR1


Document Created: 2016-03-26 00:12:41
Document Modified: 2016-03-26 00:12:41
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
FR Citation81 FR 17083 
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