81_FR_46970 81 FR 46832 - Inversions and Related Transactions; Correction

81 FR 46832 - Inversions and Related Transactions; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 138 (July 19, 2016)

Page Range46832-46833
FR Document2016-16470

This document contains corrections to a correction document for final and temporary regulations (TD 9761) that was published in the Federal Register on June 23, 2016 (81 FR 40810).

Federal Register, Volume 81 Issue 138 (Tuesday, July 19, 2016) 
[Federal Register Volume 81, Number 138 (Tuesday, July 19, 2016)]
[Rules and Regulations]
[Pages 46832-46833]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-16470]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9761]
RIN 1545-BM88


Inversions and Related Transactions; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correcting amendment.

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SUMMARY: This document contains corrections to a correction document 
for final and temporary regulations (TD 9761) that was published in the 
Federal Register on June 23, 2016 (81 FR 40810).

DATES: This correction is effective on July 19, 2016 and applicable on 
June 23, 2016.

FOR FURTHER INFORMATION CONTACT: Rose E. Jenkins at (202) 317-6934 (not 
a toll free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final and temporary regulations (TD 9761) that are the subject 
of this correction are under sections 304, 367, 956, 7701(l), and 7874 
of the Internal Revenue Code.

Correction of Publication

    In correcting amendment FR Doc. 2016-14649, published in the issue 
of Thursday, June 23, 2016 (81 FR 40810), make the following 
correction:
    On page 40811, in the first column, remove amendatory instruction 
6.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

    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:


[[Page 46833]]


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


0
Par. 2. Section 1.956-2T is amended by revising the first sentence of 
paragraph (a)(4)(iv) Example 3.(A), the second sentence of paragraph 
(a)(4)(iv) Example 3.(B), and the third sentence of paragraph 
(a)(4)(iv) Example 4.(B) to read as follows:


Sec.  1.956-2T  Definition of United States property (temporary).

* * * * *
    (a) * * *
    (4) * * *
    (iv) * * *
    Example 3. (A) Facts. Before the inversion transaction, FA also 
wholly owns USP, a domestic corporation, which, in turn, wholly owns, 
LFS, a foreign corporation that is a controlled foreign corporation. * 
* *
    (B) * * * Because LFS was a controlled foreign corporation and a 
member of the EAG with respect to the inversion transaction on the 
completion date, and DT was not a United States shareholder with 
respect to LFS on or before the completion date, LFS is excluded from 
the definition of expatriated foreign subsidiary pursuant to Sec.  
1.7874-12T(a)(9)(ii). * * *
    Example 4. * * *
    (B) * * * Because LFSS was not a member of the EAG with respect to 
the inversion transaction on the completion date, LFSS is not excluded 
from the definition of expatriated foreign subsidiary pursuant to Sec.  
1.7874-12T(a)(9)(ii). * * *
* * * * *

0
Par. 3. Section 1.7874-8T is amended by revising the ninth sentence of 
paragraph (h) Example 3.(ii) to read as follows:


Sec.  1.7874-8T  Disregard of certain stock attributable to multiple 
domestic entity acquisitions (temporary).

* * * * *
    (h) * * *
    Example 3. * * *
    (ii) * * * Accordingly, the excluded amount is $112.50x calculated 
as 150 (200, the total number of prior acquisition shares, less 50, the 
allocable redeemed shares) multiplied by $0.75x (the fair market value 
of a single share of FA stock on the completion date with respect to 
the DT2 acquisition). * * *
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2016-16470 Filed 7-18-16; 8:45 am]
 BILLING CODE 4830-01-P

46832 Federal Register / Vol. 81, No. 138 / Tuesday, July 19, 2016 / Rules and Regulations College Park, MD 20740. These forms submitted to the LACF Registration Products Inspection Act (71 Stat. 441, as also are available on the Food and Drug Coordinator (HFS–303), Center for Food amended by 82 Stat. 791 (21 U.S.C. 451 Administration’s Web site at http:// Safety and Applied Nutrition, Food and et seq.)). www.fda.gov/Food/Guidance Drug Administration, 5001 Campus Dr., * * * * * Regulation/FoodFacilityRegistration/ College Park, MD 20740. These forms Dated: July 12, 2016. AcidifiedLACFRegistration/default.htm. also are available on the Food and Drug For electronic submission go to FDA’s Administration’s Web site at http:// Leslie Kux, Industry Systems Web site at www.fda.gov/Food/ Associate Commissioner for Policy. www.access.fda.gov. Commercial GuidanceRegulation/ [FR Doc. 2016–16968 Filed 7–18–16; 8:45 am] processors duly registered in accordance FoodFacilityRegistration/ BILLING CODE 4164–01–P with this section shall notify the Food AcidifiedLACFRegistration/default.htm. and Drug Administration not later than For electronic submission, go to FDA’s 90 days after such commercial processor Industry Systems Web site at DEPARTMENT OF THE TREASURY ceases or discontinues the manufacture, www.access.fda.gov. processing, or packing of thermally * * * * * Internal Revenue Service processed foods in any establishment: (ii) If a packer intentionally makes a Provided, that such notification shall change in a previously filed scheduled 26 CFR Part 1 not be required as to the temporary process by reducing the initial [TD 9761] cessation necessitated by the seasonal temperature or retort temperature, character of the particular reducing the time of processing, or RIN 1545–BM88 establishment’s production or caused by changing the product formulation, the temporary conditions including but not Inversions and Related Transactions; container, or any other condition basic limited to strikes, lockouts, fire, or acts Correction to the adequacy of scheduled process, of God. he shall prior to using such changed AGENCY: Internal Revenue Service (IRS), (2) Process filing. A commercial process obtain substantiation by Treasury. processor engaged in the thermal qualified scientific authority as to its ACTION: Final and temporary processing of low-acid foods packaged adequacy. Such substantiation may be regulations; correcting amendment. in hermetically sealed containers shall, obtained by telephone, telegram, or not later than 60 days after registration other media, but must be promptly SUMMARY: This document contains and prior to the packing of a new recorded, verified in writing by the corrections to a correction document for product, provide the Food and Drug authority, and contained in the packer’s final and temporary regulations (TD Administration information as to the files for review by the Food and Drug 9761) that was published in the Federal scheduled processes including but not Administration. Within 30 days after Register on June 23, 2016 (81 FR 40810). limited to the processing method, type first use, the packer shall submit to the DATES: This correction is effective on of retort or other thermal processing LACF Registration Coordinator (HFS– July 19, 2016 and applicable on June 23, equipment employed, minimum initial 303), Center for Food Safety and 2016. temperatures, times and temperatures of Applied Nutrition, Food and Drug FOR FURTHER INFORMATION CONTACT: Rose processing, sterilizing value (Fo), or Administration, 5001 Campus Dr., E. Jenkins at (202) 317–6934 (not a toll other equivalent scientific evidence of College Park, MD 20740 a complete free number). process adequacy, critical control description of the modifications made SUPPLEMENTARY INFORMATION: factors affecting heat penetration, and and utilized, together with a copy of his source and date of the establishment of file record showing prior substantiation Background the process, for each such low-acid food by a qualified scientific authority as to The final and temporary regulations in each container size: Provided, that the safety of the changed process. Any (TD 9761) that are the subject of this the filing of such information does not intentional change of a previously filed correction are under sections 304, 367, constitute approval of the information scheduled process or modification 956, 7701(l), and 7874 of the Internal by the Food and Drug Administration, thereof in which the change consists Revenue Code. and that information concerning solely of a higher initial temperature, a processes and other data so filed shall higher retort temperature, or a longer Correction of Publication be regarded as trade secrets within the processing time, shall not be considered In correcting amendment FR Doc. meaning of 21 U.S.C. 331(j) and 18 a change subject to this paragraph, but 2016–14649, published in the issue of U.S.C. 1905. This information shall be if that modification is thereafter to be Thursday, June 23, 2016 (81 FR 40810), submitted on the following forms as regularly scheduled, the modified make the following correction: appropriate: Form FDA 2541d (Food process shall be promptly filed as a On page 40811, in the first column, Process Filing for Low-Acid Retorted scheduled process, accompanied by full remove amendatory instruction 6. Method), Form FDA 2541f (Food information on the specified forms as Process Filing for Water Activity/ provided in this paragraph. List of Subjects in 26 CFR Part 1 Formulation Control Method), or Form * * * * * Income taxes, Reporting and FDA 2541g (Food Process Filing for (i) This section shall not apply to the recordkeeping requirements. Low-Acid Aseptic Systems). These commercial processing of any food Accordingly, 26 CFR part 1 is forms are available from the LACF processed under the continuous corrected by making the following Registration Coordinator (HFS–303), inspection of the meat and poultry correcting amendments: ehiers on DSK5VPTVN1PROD with RULES Center for Food Safety and Applied inspection program of the Food Safety Nutrition, Food and Drug and Inspection Service of the PART 1—INCOME TAXES Administration, 5001 Campus Dr., Department of Agriculture under the College Park, MD 20740, or at any Food Federal Meat Inspection Act (34 Stat. ■ Paragraph 1. The authority citation and Drug Administration district office. 1256, as amended by 81 Stat. 584 (21 for part 1 continues to read in part as The completed form(s) shall be U.S.C. 601 et seq.)) and the Poultry follows: VerDate Sep<11>2014 13:36 Jul 18, 2016 Jkt 238001 PO 00000 Frm 00006 Fmt 4700 Sfmt 4700 E:\FR\FM\19JYR1.SGM 19JYR1

Federal Register / Vol. 81, No. 138 / Tuesday, July 19, 2016 / Rules and Regulations 46833 Authority: 26 U.S.C. 7805 * * * DEPARTMENT OF HOMELAND arrange their transits to minimize any ■ Par. 2. Section 1.956–2T is amended SECURITY impact caused by the temporary by revising the first sentence of deviation. Coast Guard In accordance with 33 CFR 117.35(e), paragraph (a)(4)(iv) Example 3.(A), the the drawbridge must return to its regular second sentence of paragraph (a)(4)(iv) 33 CFR Part 117 operating schedule immediately at the Example 3.(B), and the third sentence of end of the effective period of this paragraph (a)(4)(iv) Example 4.(B) to [Docket No. USCG–2016–0645] temporary deviation. This deviation read as follows: Drawbridge Operation Regulation; from the operating regulations is § 1.956–2T Definition of United States State Boat Channel, Captree Island, NY authorized under 33 CFR 117.35. property (temporary). Dated: July 14, 2016. * * * * * AGENCY: Coast Guard, DHS. C.J. Bisignano, ACTION: Notice of deviation from (a) * * * Supervisory Bridge Management Specialist, drawbridge regulation. (4) * * * First Coast Guard District. (iv) * * * SUMMARY: The Coast Guard has issued a [FR Doc. 2016–17006 Filed 7–18–16; 8:45 am] Example 3. (A) Facts. Before the temporary deviation from the operating BILLING CODE 9110–04–P inversion transaction, FA also wholly schedule that governs the Captree State owns USP, a domestic corporation, Parkway Bridge across the State Boat which, in turn, wholly owns, LFS, a Channel, mile 30.7 at Captree Island, DEPARTMENT OF HOMELAND foreign corporation that is a controlled New York. This deviation is necessary SECURITY foreign corporation. * * * to allow the bridge owner to perform painting and steel repairs. Coast Guard (B) * * * Because LFS was a controlled foreign corporation and a DATES: This deviation is effective from 33 CFR Part 165 member of the EAG with respect to the September 6, 2016 to December 16, inversion transaction on the completion 2016. [Docket Number USCG–2016–0555] date, and DT was not a United States ADDRESSES: The docket for this RIN 1625–AA00 shareholder with respect to LFS on or deviation, [USCG–2016–0645] is before the completion date, LFS is available at http://www.regulations.gov. Safety Zone; Navy UNDET, Apra Outer excluded from the definition of Type the docket number in the Harbor, GU expatriated foreign subsidiary pursuant ‘‘SEARCH’’ box and click ‘‘SEARCH’’. to § 1.7874–12T(a)(9)(ii). * * * AGENCY: Coast Guard, DHS. Click on Open Docket Folder on the line Example 4. * * * associated with this deviation. ACTION: Temporary final rule. (B) * * * Because LFSS was not a FOR FURTHER INFORMATION CONTACT: If SUMMARY: The Coast Guard is member of the EAG with respect to the you have questions about this temporary establishing a temporary safety zone for inversion transaction on the completion deviation, call or email Judy Leung-Yee, navigable waters within a 700-yard date, LFSS is not excluded from the Project Officer, First Coast Guard radius on the surface and 1400-yard definition of expatriated foreign District, telephone (212) 514–4330, radius underwater of the Navy subsidiary pursuant to § 1.7874– email judy.k.leung-yee@uscg.mil. underwater detonation operations in the 12T(a)(9)(ii). * * * SUPPLEMENTARY INFORMATION: waters of Apra Outer Harbor, Guam. The * * * * * The Captree State Parkway Bridge, Coast Guard believes this safety zone ■ Par. 3. Section 1.7874–8T is amended mile 30.7, across the State Boat Channel, regulation is necessary to protect all by revising the ninth sentence of has a vertical clearance in the closed persons and vessel that would otherwise paragraph (h) Example 3.(ii) to read as position of 29 feet at mean high water transit or be within the affected areas follows: and 30 feet at mean low water. The from possible safety hazards associated existing bridge operating regulations are with underwater detonation operations. § 1.7874–8T Disregard of certain stock found at 33 CFR 117.799(i). Entry of vessels or persons into these attributable to multiple domestic entity The waterway is transited by seasonal zones is prohibited unless specifically acquisitions (temporary). recreational traffic. authorized by the Captain of the Port * * * * * New York State DOT, the owner of the Guam. (h) * * * bridge, requested a temporary deviation DATES: This rule is effective from 8 a.m. Example 3. * * * from the normal operating schedule to through 4 p.m. on July 28, 2016. (ii) * * * Accordingly, the excluded perform painting and steel repairs. ADDRESSES: To view documents amount is $112.50x calculated as 150 Under this temporary deviation, the Captree State Parkway Bridge will not mentioned in this preamble as being (200, the total number of prior open for marine traffic from September available in the docket, go to http:// acquisition shares, less 50, the allocable 6, 2016 to December 16, 2016. www.regulations.gov, type USCG–2016– redeemed shares) multiplied by $0.75x Vessels able to pass under the bridge 0555 in the ‘‘SEARCH’’ box and click (the fair market value of a single share in the closed position may do so at ‘‘SEARCH.’’ Click on Open Docket of FA stock on the completion date with anytime. The bridge will not be able to Folder on the line associated with this respect to the DT2 acquisition). * * * open for emergencies and there is no rule. * * * * * FOR FURTHER INFORMATION CONTACT: If immediate alternate route for vessels to ehiers on DSK5VPTVN1PROD with RULES Martin V. Franks, pass. you have questions on this rule, call or Chief, Publications and Regulations Branch, The Coast Guard will inform the users email Chief Kristina Gauthier, Sector Legal Processing Division, Associate Chief of the waterways through our Local Guam, U.S. Coast Guard; telephone Counsel (Procedure and Administration). Notice and Broadcast to Mariners of the (671) 355–4866, email [FR Doc. 2016–16470 Filed 7–18–16; 8:45 am] change in operating schedule for the Kristina.M.Gauthier@uscg.mil. BILLING CODE 4830–01–P bridge so that vessel operations can SUPPLEMENTARY INFORMATION: VerDate Sep<11>2014 17:09 Jul 18, 2016 Jkt 238001 PO 00000 Frm 00007 Fmt 4700 Sfmt 4700 E:\FR\FM\19JYR1.SGM 19JYR1


Document Created: 2016-07-19 01:10:49
Document Modified: 2016-07-19 01:10:49
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
ActionFinal and temporary regulations; correcting amendment.
DatesThis correction is effective on July 19, 2016 and applicable on June 23, 2016.
ContactRose E. Jenkins at (202) 317-6934 (not a toll free number).
FR Citation81 FR 46832 
RIN Number1545-BM88
CFR AssociatedIncome Taxes and Reporting and Recordkeeping Requirements
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