76 FR 154 pg. 49300 - Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction
Type: RULEVolume: 76Number: 154Page: 49300
Docket number: [TD 9475]
FR document: [FR Doc. 2011-20224 Filed 8-9-11; 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 9475]
RIN 1545-BF83
Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Correcting amendment.
SUMMARY:
This document describes a correction to final regulations (TD 9475) that were published on Friday,December 18, 2009 (74 FR 67053). The regulations provide guidance regarding the qualification of certaintransactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiringcorporation is issued and distributed in the transaction. This document also contains final regulations undersection 358 that provide guidance regarding the determination of the basis of stock or securities in a reorganizationdescribed in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued anddistributed in the transaction. This document also contains final regulations under section 1502 that governreorganizations described in section 368(a)(1)(D) involving members of a consolidated group.
DATES:
This correction is effective on August 10, 2011 and is applicable on December 18, 2009.
FOR FURTHER INFORMATION CONTACT:
Bruce A. Decker, (202) 622-7790 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9475) that are the subject of this document are under sections 358, 368 and 1502 of the Internal Revenue Code.
Need for Correction
As published, the final regulations (TD 9475) contain 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 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. * * *
Par. 2. Section 1.1502-13 is amended by adding paragraph (l)(6) to read as follows:
§ 1.1502-13 Intercompany transactions.
(l) * * *
(6) Effective/applicability date. (i) In general. Paragraph (f)(7)(i) Example 4. applies to transactions occurring on or after December 18, 2009.
(ii) [Reserved]
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2011-20224 Filed 8-9-11; 8:45 am]
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