82_FR_42405 82 FR 42233 - Guidance for Determining Stock Ownership; Correction

82 FR 42233 - Guidance for Determining Stock Ownership; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 82, Issue 172 (September 7, 2017)

Page Range42233-42233
FR Document2017-18983

This document contains corrections to the final regulations (T.D. 9812) that were published in the Federal Register on Wednesday, January 18, 2017. The regulations identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation.

Federal Register, Volume 82 Issue 172 (Thursday, September 7, 2017)
[Federal Register Volume 82, Number 172 (Thursday, September 7, 2017)]
[Rules and Regulations]
[Page 42233]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2017-18983]



========================================================================
Rules and Regulations
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains regulatory documents 
having general applicability and legal effect, most of which are keyed 
to and codified in the Code of Federal Regulations, which is published 
under 50 titles pursuant to 44 U.S.C. 1510.

The Code of Federal Regulations is sold by the Superintendent of Documents. 

========================================================================


Federal Register / Vol. 82, No. 172 / Thursday, September 7, 2017 / 
Rules and Regulations

[[Page 42233]]



DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9812]
RIN 1545-BL00


Guidance for Determining Stock Ownership; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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

SUMMARY: This document contains corrections to the final regulations 
(T.D. 9812) that were published in the Federal Register on Wednesday, 
January 18, 2017. The regulations identify certain stock of a foreign 
corporation that is disregarded in calculating ownership of the foreign 
corporation for purposes of determining whether it is a surrogate 
foreign corporation.

DATES: These corrections are effective on September 7, 2017, and 
applicable beginning January 13, 2017.

FOR FURTHER INFORMATION CONTACT: Joshua G. Rabon, (202) 317-6938 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations that are the subject of this correction are 
under section 7874 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations contain errors that may prove 
to be misleading and need to be clarified.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    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:

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


0
Par. 2. Section 1.7874-4 is amended by revising paragraphs 
(i)(2)(iii)(A), (i)(2)(iii)(C) introductory text, and (i)(2)(iii)(C)(2) 
to read as follows:


Sec.  1.7874-4  Disregard of certain stock related to the domestic 
entity acquisition.

* * * * *
    (i) * * *
    (2) * * *
    (iii) * * *
    (A) A member of the expanded affiliated group, unless the holder of 
the obligation immediately before the domestic entity acquisition and 
any related transaction (or its successor) is a member of the expanded 
affiliated group after the domestic entity acquisition and all related 
transactions. See Example 6 of paragraph (j) of this section for an 
illustration of this paragraph (i)(2)(iii)(A).
* * * * *
    (C) A person, other than a member of the expanded affiliated group, 
that, before or after the domestic entity acquisition, either owns 
(applying the attribution rules of section 318(a) with the 
modifications described in section 304(c)(3)(B)) at least five percent 
(by vote or value) of the stock of (or partnership interests in) or is 
related (within the meaning of section 267 or 707(b)) to--
* * * * *
    (2) A person described in paragraph (i)(2)(iii)(B) of this section.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division 
(Associate Chief Counsel), Procedure and Administration.
[FR Doc. 2017-18983 Filed 9-6-17; 8:45 am]
 BILLING CODE 4830-01-P



                                                                                                                                                                                             42233

                                             Rules and Regulations                                                                                         Federal Register
                                                                                                                                                           Vol. 82, No. 172

                                                                                                                                                           Thursday, September 7, 2017



                                             This section of the FEDERAL REGISTER                    Correction of Publication                             ENVIRONMENTAL PROTECTION
                                             contains regulatory documents having general                                                                  AGENCY
                                             applicability and legal effect, most of which             Accordingly, 26 CFR part 1 is
                                             are keyed to and codified in the Code of                corrected by making the following                     40 CFR Part 52
                                             Federal Regulations, which is published under           correcting amendments:
                                             50 titles pursuant to 44 U.S.C. 1510.                                                                         [EPA–R01–OAR–2013–0089; A–1–FRL–
                                                                                                                                                           9967–28–Region 1]
                                                                                                     PART 1—INCOME TAXES
                                             The Code of Federal Regulations is sold by
                                             the Superintendent of Documents.                                                                              Air Plan Approval; Maine; New Motor
                                                                                                     ■ Paragraph 1. The authority citation                 Vehicle Emission Standards
                                                                                                     for part 1 continues to read in part as
                                             DEPARTMENT OF THE TREASURY                              follows:                                              AGENCY:  Environmental Protection
                                                                                                                                                           Agency.
                                             Internal Revenue Service                                    Authority: 26 U.S.C. 7805 * * *
                                                                                                                                                           ACTION: Final rule.
                                                                                                     ■  Par. 2. Section 1.7874–4 is amended
                                             26 CFR Part 1                                           by revising paragraphs (i)(2)(iii)(A),                SUMMARY:    The Environmental Protection
                                                                                                                                                           Agency (EPA) is approving a State
                                                                                                     (i)(2)(iii)(C) introductory text, and
                                             [TD 9812]                                                                                                     Implementation Plan (SIP) revision
                                                                                                     (i)(2)(iii)(C)(2) to read as follows:
                                                                                                                                                           submitted by the State of Maine on
                                                                                                     § 1.7874–4 Disregard of certain stock                 August 18, 2015. This SIP revision
                                             RIN 1545–BL00
                                                                                                     related to the domestic entity acquisition.           includes Maine’s revised regulation for
                                             Guidance for Determining Stock                          *       *     *     *     *                           new motor vehicle emission standards.
                                             Ownership; Correction                                                                                         Maine has updated its rule to be
                                                                                                        (i) * * *                                          consistent with various updates made to
                                             AGENCY: Internal Revenue Service (IRS),                    (2) * * *                                          California’s low emission vehicle (LEV)
                                             Treasury.                                                  (iii) * * *                                        program. Maine has adopted these
                                                                                                                                                           revisions to reduce emissions of volatile
                                             ACTION:   Correcting amendments.                           (A) A member of the expanded                       organic compounds (VOC) and nitrogen
                                                                                                     affiliated group, unless the holder of the            oxides (NOX) in accordance with the
                                             SUMMARY:   This document contains                       obligation immediately before the                     requirements of the Clean Air Act
                                             corrections to the final regulations (T.D.              domestic entity acquisition and any                   (CAA), as well as to reduce greenhouse
                                             9812) that were published in the                        related transaction (or its successor) is a           gases. The intended effect of this action
                                             Federal Register on Wednesday,                          member of the expanded affiliated                     is to approve Maine’s August 15, 2015
                                             January 18, 2017. The regulations                       group after the domestic entity                       SIP revision. This action is being taken
                                             identify certain stock of a foreign                     acquisition and all related transactions.             in accordance with the Clean Air Act.
                                             corporation that is disregarded in
                                                                                                     See Example 6 of paragraph (j) of this                DATES: This rule is effective on October
                                             calculating ownership of the foreign
                                                                                                     section for an illustration of this                   10, 2017.
                                             corporation for purposes of determining
                                             whether it is a surrogate foreign                       paragraph (i)(2)(iii)(A).                             ADDRESSES: EPA has established a
                                             corporation.                                            *       *     *     *     *                           docket for this action under Docket
                                                                                                        (C) A person, other than a member of               Identification No. EPA–R01–OAR–
                                             DATES: These corrections are effective                                                                        2013–0089. All documents in the docket
                                             on September 7, 2017, and applicable                    the expanded affiliated group, that,
                                                                                                     before or after the domestic entity                   are listed on the http://
                                             beginning January 13, 2017.                                                                                   www.regulations.gov Web site. Although
                                                                                                     acquisition, either owns (applying the
                                             FOR FURTHER INFORMATION CONTACT:                        attribution rules of section 318(a) with              listed in the index, some information is
                                             Joshua G. Rabon, (202) 317–6938 (not a                                                                        not publicly available, i.e., CBI or other
                                                                                                     the modifications described in section
                                             toll-free number).                                                                                            information whose disclosure is
                                                                                                     304(c)(3)(B)) at least five percent (by
                                                                                                                                                           restricted by statute. Certain other
                                             SUPPLEMENTARY INFORMATION:                              vote or value) of the stock of (or                    material, such as copyrighted material,
                                                                                                     partnership interests in) or is related               is not placed on the Internet and will be
                                             Background
                                                                                                     (within the meaning of section 267 or                 publicly available only in hard copy
                                               The final regulations that are the                    707(b)) to—                                           form. Publicly available docket
                                             subject of this correction are under                    *       *     *     *     *                           materials are available at http://
                                             section 7874 of the Internal Revenue                                                                          www.regulations.gov or at the U.S.
                                                                                                        (2) A person described in paragraph
                                             Code.                                                                                                         Environmental Protection Agency, EPA
                                                                                                     (i)(2)(iii)(B) of this section.
                                             Need for Correction                                                                                           New England Regional Office, Office of
                                                                                                     *       *     *     *     *                           Ecosystem Protection, Air Quality
pmangrum on DSK3GDR082PROD with RULES




                                               As published, the final regulations                   Martin V. Franks,                                     Planning Unit, 5 Post Office Square—
                                             contain errors that may prove to be                                                                           Suite 100, Boston, MA. EPA requests
                                                                                                     Chief, Publications and Regulations Branch,
                                             misleading and need to be clarified.                    Legal Processing Division (Associate Chief            that if at all possible, you contact the
                                             List of Subjects in 26 CFR Part 1                       Counsel), Procedure and Administration.               contact listed in the FOR FURTHER
                                                                                                     [FR Doc. 2017–18983 Filed 9–6–17; 8:45 am]            INFORMATION CONTACT section to
                                               Income taxes, Reporting and                                                                                 schedule your inspection. The Regional
                                                                                                     BILLING CODE 4830–01–P
                                             recordkeeping requirements.                                                                                   Office’s official hours of business are


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Document Created: 2017-09-07 02:01:56
Document Modified: 2017-09-07 02:01:56
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 amendments.
DatesThese corrections are effective on September 7, 2017, and applicable beginning January 13, 2017.
ContactJoshua G. Rabon, (202) 317-6938 (not a toll-free number).
FR Citation82 FR 42233 
RIN Number1545-BL00
CFR AssociatedIncome Taxes and Reporting and Recordkeeping Requirements

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