82 FR 52848 - Treatment of Certain Transfers of Property to Foreign Corporations; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 82, Issue 219 (November 15, 2017)

This document contains corrections to final regulations (TD 9803) that were published in the Federal Register on Friday, December 16, 2016. The final regulations are related to certain transfers of property by United States persons to foreign corporations.

[Federal Register Volume 82, Number 219 (Wednesday, November 15, 2017)]
[Rules and Regulations]
[Page 52848]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2017-24687]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9803]
RIN 1545-BL87


Treatment of Certain Transfers of Property to Foreign 
Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final regulations (TD 
9803) that were published in the Federal Register on Friday, December 
16, 2016. The final regulations are related to certain transfers of 
property by United States persons to foreign corporations.

DATES: This correction is effective on November 15, 2017 and is 
applicable on or after December 16, 2016.

FOR FURTHER INFORMATION CONTACT: Lynlee Baker at (202) 317-6937 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9803) that are the subject of this 
correction are issued under section 367 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations published in the Federal 
Register on Friday, December 16, 2016 (81 FR 91012) (TD 9803) contain 
an error that needs to be corrected. Specifically, paragraph (e) was 
inadvertently omitted from the final regulations.

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 amendment:

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 1.367(a)-1 is amended by adding paragraph (e) to read 
as follows:


Sec.  1.367(a)-1   Transfers to foreign corporations subject to section 
367(a): In general.

* * * * *
    (e) Close of taxable year in certain section 368(a)(1)(F) 
reorganizations. If a domestic corporation is the transferor 
corporation in a reorganization described in section 368(a)(1)(F) after 
March 30, 1987, in which the acquiring corporation is a foreign 
corporation, then the taxable year of the transferor corporation shall 
end with the close of the date of the transfer and the taxable year of 
the acquiring corporation shall end with the close of the date on which 
the transferor's taxable year would have ended but for the occurrence 
of the transfer. With regard to the consequences of the closing of the 
taxable year, see section 381 and the regulations thereunder.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2017-24687 Filed 11-14-17; 8:45 am]
 BILLING CODE 4830-01-P