70 FR 20 pgs. 5044-5045 - Section 1374 Effective Dates; Correction
Type: RULEVolume: 70Number: 20Pages: 5044 - 5045
Docket number: [TD 9170]
FR document: [FR Doc. 05-1734 Filed 1-31-05; 8:45 am]
Agency: Treasury Department
Sub Agency: Internal Revenue Service
Official PDF Version: PDF Version
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9170]
RIN 1545-BD99
Section 1374 Effective Dates; Correction
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Correcting amendment.
SUMMARY:
This document corrects temporary regulations (TD 9170) that were published in the Federal Register on Wednesday, December 22, 2004 (69 FR 76612), that provide guidance concerning the applicability of section 1374 to S corporations that acquire assets in carryover basis transactions from C corporations on or after December 27, 1994, and to certain corporations that terminate S corporation status and later elect again to become S corporations.
DATES:
This document is effective on December 22, 2004.
FOR FURTHER INFORMATION CONTACT:
Stephen R. Cleary, (202) 622-7750 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9170) that is the subject of this correction are under 1374 of the Internal Revenue Code.
Need for Correction
As published, the final and temporary regulations (TD 9170) contains an error that may prove to be misleading and are in need of clarification.
List of Subjects in 26 CFR Parts 1
Income Tax, Reporting and recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendment:
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 * * *
2. In § 1.1374-8T, the section heading, and paragraphs (a)(1) and (a)(2) are revised to read as follows:
§ 1.1374-8T 1374(d)(8) transactions (temporary).
(a)(1) (Reserved) For further guidance see § 1.1374-8(a).
(2) Section 1374(d)(8) applies to any § 1.1374(d)(8) transaction, as defined in paragraph (a)(1) of this section, that occurs on or after December 27, 1994, without regard to the date of the corporation's election to be an S corporation under section 1362.
Cynthia E. Grigsby,
Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedures and Administration).
[FR Doc. 05-1734 Filed 1-31-05; 8:45 am]
BILLING CODE 4830-01-P