thefederalregister.org Federal Register Research Archive

Document

Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction

This document contains a correction to final regulations (TD 9243), that was published in the Federal Register on Thursday, January 26, 2006 (71 FR 4276). This final regulation ...

PDF versionSource Record
Department of the Treasury
Internal Revenue Service
  1. 26 CFR Part 1
  2. [TD 9243]
  3. RIN 1545-BA65

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document contains a correction to final regulations (TD 9243), that was published in the Federal Register on Thursday, January 26, 2006 (71 FR 4276). This final regulation amends the income tax regulations under various provisions of the Internal Revenue Code to account for statutory mergers and consolidations.

DATES:

This correction is effective January 23, 2006.

FOR FURTHER INFORMATION CONTACT:

Christopher Trump (202) 622-3860 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulation (TD 9243) that is the subject of this correction is under section 367 of the Internal Revenue Code.

Need for Correction

As published, TD 9243 contains an error that may prove to be misleading and is in need of clarification.

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

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

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

[Corrected]

Par. 2. Section 1.367(b)-6 is amended by removing the third sentence of ( printed page 28267) paragraph (a)(1) and adding the following sentence in its place to read as follows:

Effective dates and coordination rules.

(a) * * *

(1) * * * Section 1.367(b)-4(b)(1)(ii) applies to all triangular reorganizations and reorganizations described in section 368(a)(1)(G) and (a)(2)(D) occurring on or after January 23, 2006, although taxpayers may apply § 1.367(b)-4(b)(1)(ii) to triangular B reorganizations occurring on or after February 23, 2000, that is not closed by the period of limitations if done consistently with respect to all such triangular B reorganizations.* * *

* * * * *

Guy R. Traynor,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedures and Administration).

[FR Doc. 06-4533 Filed 5-15-06; 8:45 am]

BILLING CODE 4830-01-P

Legal Citation

Federal Register Citation

Use this for formal legal and research references to the published document.

71 FR 28266

Web Citation

Suggested Web Citation

Use this when citing the archival web version of the document.

“Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction,” thefederalregister.org (May 16, 2006), https://thefederalregister.org/documents/06-4533/revision-of-income-tax-regulations-under-sections-367-884-and-6038b-dealing-with-statutory-mergers-or-consolidations-und.