Stock Transfer Rules: Carryover of Earnings and Taxes, 14386 [E8-5334]
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Federal Register / Vol. 73, No. 53 / Tuesday, March 18, 2008 / Rules and Regulations
Dated: March 6, 2008.
Bernadette Dunham,
Director, Center for Veterinary Medicine.
[FR Doc. E8–5450 Filed 3–17–08; 8:45 am]
‘‘§§ 1.338–11 and 1.338–11T(d)’’ and
adding the language ‘‘§ 1.338–11’’ in its
place.
Cynthia Grigsby,
Senior Federal Register Liaison Officer,
Publications and Regulations Branch, Legal
Processing Division, Office of Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. E8–5333 Filed 3–17–08; 8:45 am]
BILLING CODE 4160–01–S
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read, in part, as
follows:
I
Authority: 26 U.S.C. 7805. * * *
BILLING CODE 4830–01–P
Par. 2. Section 1.367(b)–6 is amended
by revising paragraph (a)(1) to read as
follows:
[TD 9377]
DEPARTMENT OF THE TREASURY
§ 1.367(b)–6 Effective dates and
coordination rules.
RIN 1545–BF02
Internal Revenue Service
Application of Section 338 to
Insurance Companies; Correction
26 CFR Part 1
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendment.
[TD 9273]
SUMMARY: This document contains a
correction to final regulations (TD 9377)
that were published in the Federal
Register on Wednesday, January 23,
2008 (73 FR 3868), that apply to a
section 197 intangible resulting from an
assumption reinsurance transaction, and
under section 338 that apply to reserve
increases after a deemed asset sale.
DATES: This correction is effective on
March 18, 2008.
FOR FURTHER INFORMATION CONTACT:
William T. Sullivan (202) 622–7052 (not
toll-free number).
SUPPLEMENTARY INFORMATION:
Stock Transfer Rules: Carryover of
Earnings and Taxes
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
AGENCY:
Background
The final regulations (TD 9377) that is
the subject of this correction is under
section 197 of the Internal Revenue
Code.
Need for Correction
As published, TD 9377 contains an
error that may prove to be misleading
and is in need of clarification.
Correction of Publication
Need for Correction
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendment:
I
As published, final regulations (TD
9273) contain errors that may prove to
be misleading and are in need of
clarification.
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read as follows:
rwilkins on PROD1PC63 with PROPOSALS
§ 1.1060–1
16:03 Mar 17, 2008
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Correction of Publication
[Corrected]
I Par. 2. Section 1.1060–1(a)(2)(iii)
introductory text, last sentence is
amended by removing the language
VerDate Aug<31>2005
SUMMARY: This document contains a
correction to final regulations (TD 9273)
that were published in the Federal
Register on Tuesday, August 8, 2006 (71
FR 44887) addressing the carryover of
certain tax attributes, such as earnings
and profits and foreign income tax
accounts, when two corporations
combine in a corporate reorganization or
liquidation that is described in both
sections 367(b) and 381 of the Internal
Revenue Code.
DATES: This correction is effective
March 18, 2008.
FOR FURTHER INFORMATION CONTACT:
Jeffrey L. Parry at (202) 622–3050 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
The final regulations (TD 9273) that
are the subject of this correction are
under section 367(b) of the Internal
Revenue Code.
Income taxes, Reporting and
recordkeeping requirements.
Authority: 26 U.S.C. 7805. * * *
Internal Revenue Service (IRS),
Treasury.
ACTION: Correction to final regulations.
AGENCY:
Background
List of Subjects 26 CFR Part 1
I
RIN 1545–AX65
Jkt 214001
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendment:
I
PO 00000
Frm 00016
Fmt 4700
Sfmt 4700
I
(a) Effective date. (1) In general.
Except as otherwise provided in this
paragraph (a)(1), §§ 1.367(b)–1 through
1.367(b)–5, and this section, apply to
section 367(b) exchanges that occur on
or after February 23, 2000. The rules of
§§ 1.367(b)–3 and 1.367(b)–4, as they
apply to reorganizations described in
section 368(a)(1)(A) (including
reorganizations described in section
368(a)(2)(D) or (E)) involving a foreign
acquiring or foreign acquired
corporation, apply only to transfers
occurring on or after January 23, 2006.
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,
in a taxable year that is not closed by
the period of limitations if done
consistently with respect to all such
triangular B reorganizations. The second
sentence of paragraph (a) in § 1.367(b)–
4 shall apply to section 304(a)(1)
transactions occurring on or after
February 23, 2006; however, taxpayers
may rely on this sentence for all section
304(a)(1) transactions occurring in open
taxable years. Section 1.367(b)–
1(c)(2)(v), (c)(3)(ii)(A), (c)(4)(iv),
(c)(4)(v), 1.367(b)–2(j)(1)(i), (l), and
1.367(b)–3(e) and (f), apply to section
367(b) exchanges that occur on or after
November 6, 2006. For guidance with
respect to § 1.367(b)–1(c)(3)(ii)(A) and
(c)(4)(iv) and (v) and § 1.367(b)–2(j)(1)(i)
for exchanges that occur before
November 6, 2006, see 26 CFR part 1
revised as of April 1, 2006.
*
*
*
*
*
La Nita VanDyke,
Branch Chief, Publications and Regulations
Branch, Legal Processing Division, Associate
Chief Counsel (Procedure and
Administration).
[FR Doc. E8–5334 Filed 3–17–08; 8:45 am]
BILLING CODE 4830–01–P
E:\FR\FM\18MRR1.SGM
18MRR1
]]>Agencies
[Federal Register Volume 73, Number 53 (Tuesday, March 18, 2008)]
[Rules and Regulations]
[Page 14386]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-5334]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9273]
RIN 1545-AX65
Stock Transfer Rules: Carryover of Earnings and Taxes
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to final regulations.
-----------------------------------------------------------------------
SUMMARY: This document contains a correction to final regulations (TD
9273) that were published in the Federal Register on Tuesday, August 8,
2006 (71 FR 44887) addressing the carryover of certain tax attributes,
such as earnings and profits and foreign income tax accounts, when two
corporations combine in a corporate reorganization or liquidation that
is described in both sections 367(b) and 381 of the Internal Revenue
Code.
DATES: This correction is effective March 18, 2008.
FOR FURTHER INFORMATION CONTACT: Jeffrey L. Parry at (202) 622-3050
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9273) that are the subject of this
correction are under section 367(b) of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9273) contain errors that may
prove to be misleading and are in need of clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Correction of Publication
0
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(b)-6 is amended by revising paragraph (a)(1) to
read as follows:
Sec. 1.367(b)-6 Effective dates and coordination rules.
(a) Effective date. (1) In general. Except as otherwise provided in
this paragraph (a)(1), Sec. Sec. 1.367(b)-1 through 1.367(b)-5, and
this section, apply to section 367(b) exchanges that occur on or after
February 23, 2000. The rules of Sec. Sec. 1.367(b)-3 and 1.367(b)-4,
as they apply to reorganizations described in section 368(a)(1)(A)
(including reorganizations described in section 368(a)(2)(D) or (E))
involving a foreign acquiring or foreign acquired corporation, apply
only to transfers occurring on or after January 23, 2006. 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
Sec. 1.367(b)-4(b)(1)(ii) to triangular B reorganizations occurring on
or after February 23, 2000, in a taxable year that is not closed by the
period of limitations if done consistently with respect to all such
triangular B reorganizations. The second sentence of paragraph (a) in
Sec. 1.367(b)-4 shall apply to section 304(a)(1) transactions
occurring on or after February 23, 2006; however, taxpayers may rely on
this sentence for all section 304(a)(1) transactions occurring in open
taxable years. Section 1.367(b)-1(c)(2)(v), (c)(3)(ii)(A), (c)(4)(iv),
(c)(4)(v), 1.367(b)-2(j)(1)(i), (l), and 1.367(b)-3(e) and (f), apply
to section 367(b) exchanges that occur on or after November 6, 2006.
For guidance with respect to Sec. 1.367(b)-1(c)(3)(ii)(A) and
(c)(4)(iv) and (v) and Sec. 1.367(b)-2(j)(1)(i) for exchanges that
occur before November 6, 2006, see 26 CFR part 1 revised as of April 1,
2006.
* * * * *
La Nita VanDyke,
Branch Chief, Publications and Regulations Branch, Legal Processing
Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E8-5334 Filed 3-17-08; 8:45 am]
BILLING CODE 4830-01-P
