81 FR 91888 - Guidance Regarding Predecessors and Successors Under Section 355(e); Limitation on Gain Recognition; Guidance Under Section 355(f)

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 243 (December 19, 2016)

Page Range		91888-91889
FR Document		2016-30156

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. Those temporary regulations affect corporations that distribute the stock or securities of controlled corporations and their shareholders or security holders of those distributing corporations. The text of those temporary regulations serves as the text of these proposed regulations.

Federal Register, Volume 81 Issue 243 (Monday, December 19, 2016)

[Federal Register Volume 81, Number 243 (Monday, December 19, 2016)]
[Proposed Rules]
[Pages 91888-91889]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-30156]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-140328-15]
RIN 1545-BN17


Guidance Regarding Predecessors and Successors Under Section 
355(e); Limitation on Gain Recognition; Guidance Under Section 355(f)

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking, notice of proposed 
rulemaking by cross-reference to temporary regulations.

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

SUMMARY: In the Rules and Regulations section of this issue of the 
Federal Register, the IRS is issuing temporary regulations that provide 
guidance regarding the distribution by a distributing corporation of 
stock or securities of a controlled corporation without the recognition 
of income, gain, or loss. The temporary regulations provide guidance in 
determining whether a corporation is a predecessor or successor of a 
distributing or controlled corporation for purposes of the exception 
under section 355(e) of the Internal Revenue Code to the nonrecognition 
treatment afforded qualifying distributions, and they provide certain 
limitations on the recognition of gain in certain cases involving a 
predecessor of a distributing corporation. The temporary regulations 
also provide rules regarding the extent to which section 355(f) causes 
a distributing corporation (and in certain cases its shareholders) to 
recognize income or gain on the distribution of stock or securities of 
a controlled corporation. Those temporary regulations affect 
corporations that distribute the stock or securities of controlled 
corporations and their shareholders or security holders of those 
distributing corporations. The text of those temporary regulations 
serves as the text of these proposed regulations.

DATES: Comments and requests for a public hearing must be received by 
March 20, 2017.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-140328-15), Room 
5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
140328-15), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW., Washington, DC 20224, or sent electronically, via the 
Federal eRulemaking Portal at http://www.regulations.gov/ (REG-140328-
15).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Richard K. Passales at (202) 317-5024 or Marie C. Milnes-Vasquez, (202) 
317-7700; concerning submission of comments, and/or requests for public 
hearing, Regina Johnson at (202) 317-6901 (not toll-free numbers).

SUPPLEMENTARY INFORMATION: 

Background and Explanation of Provisions

    On November 22, 2004, the Treasury Department and the IRS published 
in the Federal Register (69 FR 67873) a

[[Page 91889]]

notice of proposed rulemaking (REG-145535-02) containing proposed 
regulations under section 355(e)(4)(D) (the 2004 proposed regulations). 
Those proposed regulations are withdrawn. This notice of proposed 
rulemaking cross-references to temporary regulations contained in a 
Treasury decision published in the Rules and Regulations section of 
this issue of the Federal Register which amend the Income Tax 
Regulations (26 CFR part 1) relating to section 355(e) by adopting the 
2004 proposed regulations with certain significant modifications. The 
Background and Explanation of Provisions contained in the preamble of 
the temporary regulations also serves as part of this preamble.

Special Analyses

    Certain IRS regulations, including this one, are exempt from the 
requirements of Executive Order 12866, as supplemented and reaffirmed 
by Executive Order 13653. Therefore, a regulatory impact assessment is 
not required. Pursuant to the Regulatory Flexibility Act (5 U.S.C. 
chapter 6), it is hereby certified that these proposed regulations 
would not have a significant economic impact on a substantial number of 
small entities. This certification is based on the fact that these 
proposed regulations would primarily affect large corporations with a 
substantial number of shareholders, as well as corporations that are 
members of large corporate groups. Therefore, a regulatory flexibility 
analysis is not required. Pursuant to section 7805(f) of the Code, this 
regulation has been submitted to the Chief Counsel for Advocacy of the 
Small Business Administration for comment on its impact on small 
business.

Comments and Requests for Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any comments that are submitted timely 
to the IRS as prescribed in this preamble under the ADDRESSES heading. 
The Treasury Department and the IRS request comments on all aspects of 
the proposed rules. All comments will be available at 
www.regulations.gov or upon request. A public hearing will be scheduled 
if requested in writing by any person that timely submits written 
comments. If a public hearing is scheduled, notice of the date, time, 
and place for the hearing will be published in the Federal Register.

Drafting Information

    The principal author of these regulations is Lynlee C. Baker, 
formerly of the Office of Associate Chief Counsel (Corporate). However, 
other personnel from the Treasury Department and the IRS participated 
in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Withdrawal of Notice of Proposed Rulemaking

    Accordingly, under the authority of 26 U.S.C. 7805, the notice of 
proposed rulemaking (REG-145535-02) that was published in the Federal 
Register on Monday, November 22, 2004 (69 FR 67873) is withdrawn.

Proposed Amendments to the Regulations

    Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 is amended by adding an 
entry in numerical order to read in part as follows:

    Authority:  26 U.S.C. 7805 * * *
    Section 1.355-8 also issued under 26 U.S.C. 336(e) and 
355(e)(5).

0
Par. 2. Section 1.355-0 is amended by revising the introductory text 
and adding an entry for Sec.  1.355-8 to read as follows:


Sec.  1.355-0   Outline of sections.

    In order to facilitate the use of Sec. Sec.  1.355-1 through 1.355-
8, this section lists the major paragraphs in those sections as 
follows:
* * * * *
Sec.  1.355-8 Definition of predecessor and successor and 
limitations on gain recognition under section 355(e) and section 
355(f).

    (a) In general.
    (1) Scope.
    (2) Purpose.
    (3) Overview.
    (4) References.
    (i) References to Distributing or Controlled.
    (ii) References to a Plan or distribution.
    (iii) Plan Period.
    (b) Predecessor of Distributing.
    (1) Definition.
    (i) In general.
    (ii) Pre-distribution requirements.
    (A) Relevant Property.
    (B) Reflection of basis.
    (iii) Post-distribution requirement.
    (2) Additional definitions and rules related to paragraph (b)(1) 
of this section.
    (i) References to Distributing and Controlled.
    (ii) Potential Predecessor.
    (iii) Successors of Potential Predecessors.
    (iv) Relevant Property; Relevant Stock.
    (A) In general.
    (B) Property held by Distributing.
    (C) Certain reorganizations.
    (v) Stock of Distributing as Relevant Property.
    (A) In general.
    (B) Certain reorganizations.
    (vi) Substitute Asset.
    (vii) Separated Property.
    (viii) Underlying Property.
    (ix) Scope of definition of Predecessor of Distributing.
    (x) Deemed exchanges.
    (c) Additional definitions.
    (1) Predecessor of Controlled.
    (2) Successors.
    (i) In general.
    (ii) Determination of Successor status.
    (3) Section 381 transaction.
    (d) Special acquisition rules.
    (1) Deemed acquisitions of stock in section 381 transactions.
    (2) Deemed acquisitions of stock after section 381 transactions.
    (3) Separate counting for Distributing and each Predecessor of 
Distributing.
    (e) Special rules for gain recognition.
    (1) In general.
    (2) Planned 50-percent or greater acquisitions of a Predecessor 
of Distributing.
    (i) In general.
    (ii) Operating rules.
    (A) Separated Property other than Controlled stock.
    (B) Controlled stock that is Separated Property.
    (C) Anti-duplication rule.
    (3) Planned 50-percent Acquisition of Distributing in a section 
381 transaction.
    (4) Overall gain recognition.
    (5) Section 336(e) election.
    (f) Predecessor or Successor as a member of the affiliated 
group.
    (g) Inapplicability of section 355(f) to certain intra-group 
distributions.
    (1) In general.
    (2) Alternative application of section 355(f).
    (h) Examples.
    (i) Effective/applicability date.
    (1) In general.
    (2) Transition rule.
    (i) In general.
    (ii) Definition of distribution.
    (3) Exception.
0
Par. 3. Section 1.355-8 is revised to read as follows:


Sec.  1.355-8   Definition of predecessor and successor and limitations 
on gain recognition under section 355(e) and section 355(f).

    [The text of the proposed amendments to Sec.  1.355-8(a) through 
(i) is the same as the text of Sec.  1.355-8T published elsewhere in 
this issue of the Federal Register.]

John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2016-30156 Filed 12-16-16; 8:45 am]
 BILLING CODE 4830-01-P

91888 Federal Register / Vol. 81, No. 243 / Monday, December 19, 2016 / Proposed Rules

Integrity of the Primary and Secondary Load Airplane Directorate, FAA, 1601 Lind SUMMARY: In the Rules and Regulations
Paths, of Airbus A340 ALS Part 3—CMR, Avenue SW., Renton, WA 98057–3356; section of this issue of the Federal
Revision 03, dated October 19, 2015; and do telephone 425–227–1138; fax 425–227–1149. Register, the IRS is issuing temporary
all applicable corrective actions. Do all Information may be emailed to: 9-ANM-116- regulations that provide guidance
applicable corrective actions before further ACO-AMOC-REQUESTS@faa.gov. Before
flight using a method approved by the using any approved AMOC, notify your
regarding the distribution by a
Manager, International Branch, ANM–116, appropriate principal inspector, or lacking a distributing corporation of stock or
Transport Airplane Directorate, FAA; or the principal inspector, the manager of the local securities of a controlled corporation
EASA; or Airbus’s EASA DOA. Repeat Task flight standards district office/certificate without the recognition of income, gain,
274000–B0002–1–C, Inspection of the Ball- holding district office. The AMOC approval or loss. The temporary regulations
screw Assembly for Integrity of the Primary letter must specifically reference this AD. provide guidance in determining
and Secondary Load Paths, thereafter at the (2) Contacting the Manufacturer: As of the whether a corporation is a predecessor
applicable intervals specified in Airbus A340 effective date of this AD, for any requirement or successor of a distributing or
ALS Part 3—CMR, Revision 03, dated in this AD to obtain corrective actions from
October 19, 2015.
controlled corporation for purposes of
a manufacturer, the action must be the exception under section 355(e) of
(q) Parts Installation Prohibitions accomplished using a method approved by
the Manager, International Branch, ANM–
the Internal Revenue Code to the
(1) For all airplanes except Group 2 116, Transport Airplane Directorate, FAA; or nonrecognition treatment afforded
airplanes as identified in figure 1 to EASA; or Airbus’s EASA DOA. If approved qualifying distributions, and they
paragraphs (g), (h), and (p) of this AD: After by the DOA, the approval must include the provide certain limitations on the
modification of the airplane as required by DOA-authorized signature. recognition of gain in certain cases
paragraph (h), (i), or (j) of this AD, as involving a predecessor of a distributing
applicable, no person may install any THSA (t) Related Information
having P/N 47172–300, P/N 47147–500, P/N
corporation. The temporary regulations
(1) Refer to Continuing Airworthiness also provide rules regarding the extent
47175–200, or P/N 47175–300. Information (MCAI) EASA Airworthiness
(2) For Group 2 airplanes, as identified in to which section 355(f) causes a
Directive 2014–0219, dated September 29,
figure 1 to paragraphs (g), (h), and (p) of this 2014, for related information. This MCAI
distributing corporation (and in certain
AD: As of the effective date of this AD, no may be found in the AD docket on the cases its shareholders) to recognize
person may install on any Group 2 airplane Internet at http://www.regulations.gov by income or gain on the distribution of
any THSA having P/N 47172–300, P/N searching for and locating Docket No. FAA– stock or securities of a controlled
47147–500, P/N 47175–200, or P/N 47175– 2016–9393. corporation. Those temporary
300. (2) For service information identified in regulations affect corporations that
(r) Credit for Previous Actions this AD, contact Airbus SAS, Airworthiness distribute the stock or securities of
Office—EAL, 1 Rond Point Maurice Bellonte, controlled corporations and their
This paragraph provides credit for actions
31707 Blagnac Cedex, France; telephone +33 shareholders or security holders of those
required by paragraph (g)(2) of this AD, if
5 61 93 36 96; fax +33 5 61 93 45 80; email
those actions were performed before the distributing corporations. The text of
effective date of this AD using the applicable airworthiness.A330-A340@airbus.com;
Internet http://www.airbus.com. those temporary regulations serves as
service information specified in paragraphs the text of these proposed regulations.
(r)(1) through (r)(4) of this AD. (3) You may view this service information
at the FAA, Transport Airplane Directorate, DATES: Comments and requests for a
(1) Task 274400–00002–1–E, Lubrication of
the THSA ball-nut, of Airbus A330 ALS Part 1601 Lind Avenue SW., Renton, WA. For public hearing must be received by
4—Ageing Systems Maintenance, Revision information on the availability of this March 20, 2017.
03, dated September 9, 2011 (for Model A330 material at the FAA, call 425–227–1221. ADDRESSES: Send submissions to:
series airplanes). Issued in Renton, Washington, on CC:PA:LPD:PR (REG–140328–15), Room
(2) Task 274400–00002–1–E, Lubrication of November 10, 2016. 5203, Internal Revenue Service, P.O.
the THSA ball-nut, of Airbus A330 ALS Part Michael Kaszycki, Box 7604, Ben Franklin Station,
4—Ageing Systems Maintenance, Revision
04, dated August 27, 2013 (for Model A330 Acting Manager, Transport Airplane Washington, DC 20044. Submissions
series airplanes). Directorate, Aircraft Certification Service. may be hand-delivered Monday through
(3) Task 274400–00002–1–E, Lubrication of [FR Doc. 2016–29683 Filed 12–16–16; 8:45 am] Friday between the hours of 8 a.m. and
the THSA ball-nut, of Airbus A340 ALS Part BILLING CODE 4910–13–P 4 p.m. to CC:PA:LPD:PR (REG–140328–
4—Ageing Systems Maintenance, Revision 15), Courier’s Desk, Internal Revenue
02, dated October 12, 2011 (for Model A340– Service, 1111 Constitution Avenue NW.,
200 and –300 series airplanes). Washington, DC 20224, or sent
(4) Task 274400–00002–1–E, Lubrication of DEPARTMENT OF THE TREASURY
electronically, via the Federal
the THSA ball-nut, of Airbus A340 ALS Part
4—Ageing Systems Maintenance, Revision Internal Revenue Service eRulemaking Portal at http://
03, dated November 15, 2012 (for Model www.regulations.gov/ (REG–140328–
A340–200 and –300 series airplanes). 26 CFR Part 1 15).
(s) Other FAA AD Provisions [REG–140328–15] FOR FURTHER INFORMATION CONTACT:
The following provisions also apply to this
Concerning the proposed regulations,
RIN 1545–BN17 Richard K. Passales at (202) 317–5024 or
AD:
(1) Alternative Methods of Compliance Marie C. Milnes-Vasquez, (202) 317–
Guidance Regarding Predecessors and 7700; concerning submission of
(AMOCs): The Manager, International
Branch, ANM–116, Transport Airplane
Successors Under Section 355(e); comments, and/or requests for public
Directorate, FAA, has the authority to Limitation on Gain Recognition; hearing, Regina Johnson at (202) 317–
sradovich on DSK3GMQ082PROD with PROPOSALS

approve AMOCs for this AD, if requested Guidance Under Section 355(f) 6901 (not toll-free numbers).
using the procedures found in 14 CFR 39.19.
AGENCY: Internal Revenue Service (IRS), SUPPLEMENTARY INFORMATION:
In accordance with 14 CFR 39.19, send your
request to your principal inspector or local Treasury. Background and Explanation of
Flight Standards District Office, as ACTION: Withdrawal of notice of Provisions
appropriate. If sending information directly proposed rulemaking, notice of
to the International Branch, send it to ATTN: On November 22, 2004, the Treasury
proposed rulemaking by cross-reference
Vladimir Ulyanov, Aerospace Engineer, Department and the IRS published in
to temporary regulations.
International Branch, ANM–116, Transport the Federal Register (69 FR 67873) a

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Federal Register / Vol. 81, No. 243 / Monday, December 19, 2016 / Proposed Rules 91889

notice of proposed rulemaking (REG– Drafting Information (iv) Relevant Property; Relevant Stock.
145535–02) containing proposed (A) In general.
The principal author of these (B) Property held by Distributing.
regulations under section 355(e)(4)(D) regulations is Lynlee C. Baker, formerly (C) Certain reorganizations.
(the 2004 proposed regulations). Those of the Office of Associate Chief Counsel (v) Stock of Distributing as Relevant
proposed regulations are withdrawn. (Corporate). However, other personnel Property.
This notice of proposed rulemaking from the Treasury Department and the (A) In general.
cross-references to temporary IRS participated in their development. (B) Certain reorganizations.
regulations contained in a Treasury (vi) Substitute Asset.
decision published in the Rules and List of Subjects in 26 CFR Part 1 (vii) Separated Property.
Regulations section of this issue of the Income taxes, Reporting and (viii) Underlying Property.
recordkeeping requirements. (ix) Scope of definition of Predecessor of
Federal Register which amend the Distributing.
Income Tax Regulations (26 CFR part 1) Withdrawal of Notice of Proposed (x) Deemed exchanges.
relating to section 355(e) by adopting Rulemaking (c) Additional definitions.
the 2004 proposed regulations with (1) Predecessor of Controlled.
certain significant modifications. The Accordingly, under the authority of (2) Successors.
26 U.S.C. 7805, the notice of proposed (i) In general.
Background and Explanation of
rulemaking (REG–145535–02) that was (ii) Determination of Successor status.
Provisions contained in the preamble of
published in the Federal Register on (3) Section 381 transaction.
the temporary regulations also serves as (d) Special acquisition rules.
Monday, November 22, 2004 (69 FR
part of this preamble. 67873) is withdrawn. (1) Deemed acquisitions of stock in section
381 transactions.
Special Analyses Proposed Amendments to the (2) Deemed acquisitions of stock after
Certain IRS regulations, including this Regulations section 381 transactions.
(3) Separate counting for Distributing and
one, are exempt from the requirements Accordingly, 26 CFR part 1 is
each Predecessor of Distributing.
of Executive Order 12866, as proposed to be amended as follows: (e) Special rules for gain recognition.
supplemented and reaffirmed by (1) In general.
Executive Order 13653. Therefore, a PART 1—INCOME TAXES (2) Planned 50-percent or greater
regulatory impact assessment is not acquisitions of a Predecessor of Distributing.
■ Paragraph 1. The authority citation
required. Pursuant to the Regulatory (i) In general.
for part 1 is amended by adding an entry (ii) Operating rules.
Flexibility Act (5 U.S.C. chapter 6), it is in numerical order to read in part as (A) Separated Property other than
hereby certified that these proposed follows: Controlled stock.
regulations would not have a significant (B) Controlled stock that is Separated
Authority: 26 U.S.C. 7805 * * *
economic impact on a substantial Section 1.355–8 also issued under 26 Property.
number of small entities. This U.S.C. 336(e) and 355(e)(5). (C) Anti-duplication rule.
certification is based on the fact that (3) Planned 50-percent Acquisition of
■ Par. 2. Section 1.355–0 is amended by Distributing in a section 381 transaction.
these proposed regulations would revising the introductory text and
primarily affect large corporations with (4) Overall gain recognition.
adding an entry for § 1.355–8 to read as (5) Section 336(e) election.
a substantial number of shareholders, as follows: (f) Predecessor or Successor as a member
well as corporations that are members of of the affiliated group.
large corporate groups. Therefore, a § 1.355–0 Outline of sections. (g) Inapplicability of section 355(f) to
regulatory flexibility analysis is not In order to facilitate the use of certain intra-group distributions.
required. Pursuant to section 7805(f) of §§ 1.355–1 through 1.355–8, this section (1) In general.
the Code, this regulation has been lists the major paragraphs in those (2) Alternative application of section
submitted to the Chief Counsel for sections as follows: 355(f).
(h) Examples.
Advocacy of the Small Business * * * * * (i) Effective/applicability date.
Administration for comment on its § 1.355–8 Definition of predecessor and (1) In general.
impact on small business. successor and limitations on gain (2) Transition rule.
recognition under section 355(e) and (i) In general.
Comments and Requests for Public section 355(f). (ii) Definition of distribution.
Hearing (a) In general. (3) Exception.
(1) Scope.
Before these proposed regulations are (2) Purpose. ■ Par. 3. Section 1.355–8 is revised to
adopted as final regulations, (3) Overview. read as follows:
consideration will be given to any (4) References.
(i) References to Distributing or Controlled. § 1.355–8 Definition of predecessor and
comments that are submitted timely to successor and limitations on gain
the IRS as prescribed in this preamble (ii) References to a Plan or distribution.
(iii) Plan Period. recognition under section 355(e) and
under the ADDRESSES heading. The (b) Predecessor of Distributing. section 355(f).
Treasury Department and the IRS (1) Definition. [The text of the proposed
request comments on all aspects of the (i) In general. amendments to § 1.355–8(a) through (i)
proposed rules. All comments will be (ii) Pre-distribution requirements.
sradovich on DSK3GMQ082PROD with PROPOSALS

is the same as the text of § 1.355–8T
available at www.regulations.gov or (A) Relevant Property.
published elsewhere in this issue of the
upon request. A public hearing will be (B) Reflection of basis.
(iii) Post-distribution requirement. Federal Register.]
scheduled if requested in writing by any
(2) Additional definitions and rules related John Dalrymple,
person that timely submits written
to paragraph (b)(1) of this section.
comments. If a public hearing is (i) References to Distributing and Deputy Commissioner for Services and
scheduled, notice of the date, time, and Controlled. Enforcement.
place for the hearing will be published (ii) Potential Predecessor. [FR Doc. 2016–30156 Filed 12–16–16; 8:45 am]
in the Federal Register. (iii) Successors of Potential Predecessors. BILLING CODE 4830–01–P

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Document Created: 2016-12-17 03:15:24
Document Modified: 2016-12-17 03:15:24

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		Proposed Rules
Action		Withdrawal of notice of proposed rulemaking, notice of proposed rulemaking by cross-reference to temporary regulations.
Dates		Comments and requests for a public hearing must be received by March 20, 2017.
Contact		Concerning the proposed regulations, Richard K. Passales at (202) 317-5024 or Marie C. Milnes-Vasquez, (202) 317-7700; concerning submission of comments, and/or requests for public hearing, Regina Johnson at (202) 317-6901 (not toll-free numbers).
FR Citation		81 FR 91888
RIN Number		1545-BN17
CFR Associated		Income Taxes and Reporting and Recordkeeping Requirements

81 FR 91888 - Guidance Regarding Predecessors and Successors Under Section 355(e); Limitation on Gain Recognition; Guidance Under Section 355(f)

DEPARTMENT OF THE TREASURYInternal Revenue Service

Federal Register Volume 81, Issue 243 (December 19, 2016)

DEPARTMENT OF THE TREASURY
Internal Revenue Service