Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Treatment of Gain Recognized Under Section 301(c)(3) for Purposes of Section 1248; Correction, 10174 [E9-4997]

Download as PDF 10174 Federal Register / Vol. 74, No. 45 / Tuesday, March 10, 2009 / Rules and Regulations rule for effect without first soliciting public comment as requiring public comment before extending the effective date would be contrary to the interest of justice and the public interest. List of Subjects in 24 CFR Part 3500 Consumer protection, Condominiums, Housing, Mortgagees, Mortgage servicing, Reporting and recordkeeping requirements. Accordingly, 24 CFR part 3500 is corrected by making the following amendments: ■ PART 3500—REAL ESTATE SETTLEMENT PROCEDURES ACT 1. The authority citation for part 3500 continues to read as follows: ■ Authority: 12 U.S.C. 2601 et seq: 42 U.S.C. 3535(d). 2. Section 3500.1(b)(1) is revised to read as follows: ■ § 3500.1 Designation and applicability. * * * * * (b) * * * (1) The definition of Required use in § 3500.2 is applicable commencing on July 16, 2009; §§ 3500.8(b), 3500.17, 3500.21, 3500.22 and 3500.23, and Appendices E and MS–1 are applicable commencing January 16, 2009. * * * * * Dated: March 6, 2009. Brian D. Montgomery, Assistant Secretary for Housing—Federal Housing Commissioner. [FR Doc. E9–5221 Filed 3–9–09; 8:45 am] Wednesday, February 11, 2009, under sections 367(a), 367(b) and 1248(a) of the Internal Revenue Code. The final regulations under section 367 revise existing final regulations and add crossreferences. The final regulations under section 1248 update an effective/ applicability date. The temporary regulations under section 367(a) and (b) revise existing final regulations concerning transfers of stock to a foreign corporation that are described in section 351 by reason of section 304(a)(1). The temporary regulations under section 1248(a) provide that, for purposes of section 1248(a), gain recognized by a shareholder under section 301(c)(3) in connection with the receipt of a distribution of property from a foreign corporation with respect to its stock shall be treated as gain from the sale or exchange of the stock of such foreign corporation. The temporary regulations affect certain persons that transfer stock to a foreign corporation in a transaction described in section 304(a)(1), or certain persons that recognize gain under section 301(c)(3) in connection with the receipt of a distribution of property from a foreign corporation with respect to its stock. DATES: This correction is effective March 10, 2009, and is applicable on February 11, 2009. FOR FURTHER INFORMATION CONTACT: Sean W. Mullaney, (202) 622–3860 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background BILLING CODE 4210–67–P DEPARTMENT OF THE TREASURY The final and temporary regulations that are the subject of this document are under sections 367 and 1248 of the Internal Revenue Code. Internal Revenue Service Need for Correction 26 CFR Part 1 As published Wednesday, February 11, 2009 (74 FR 6824), final and temporary regulations (TD 9444) contains an error that may prove to be misleading and is in need of clarification. [TD 9444] RIN 1545–BI42 Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Treatment of Gain Recognized Under Section 301(c)(3) for Purposes of Section 1248; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correction to final and temporary regulations. SUMMARY: This document contains a correction to final and temporary regulations (TD 9444) that were published in the Federal Register on VerDate Nov<24>2008 14:58 Mar 09, 2009 Jkt 217001 Correction of Publication Accordingly, the publication of the final and temporary regulations (TD 9444), which was the subject of FR Doc. E9–2835, is corrected as follows: On page 6825, column 2, in the preamble, under the paragraph heading ‘‘A. Modified Application of Section 367(a) to Deemed Section 351 Exchanges’’, first paragraph of the column, fourth line from the bottom of the paragraph, the language ‘‘recognized $100x gain under section’’ is corrected PO 00000 Frm 00010 Fmt 4700 Sfmt 4700 to read ‘‘recognize $100x gain under section’’. Guy Traynor, Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration). [FR Doc. E9–4997 Filed 3–9–09; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9444] RIN 1545–BI42 Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Treatment of Gain Recognized Under Section 301(c)(3) for Purposes of Section 1248; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. SUMMARY: This document contains a correction to final and temporary regulations (TD 9444) that were published in the Federal Register on Wednesday, February 11, 2009, under sections 367(a), 367(b) and 1248(a) of the Internal Revenue Code. The final regulations under section 367 revise existing final regulations and add crossreferences. The final regulations under section 1248 update an effective/applicability date. The temporary regulations under section 367(a) and (b) revise existing final regulations concerning transfers of stock to a foreign corporation that are described in section 351 by reason of section 304(a)(1). The temporary regulations under section 1248(a) provide that, for purposes of section 1248(a), gain recognized by a shareholder under section 301(c)(3) in connection with the receipt of a distribution of property from a foreign corporation with respect to its stock shall be treated as gain from the sale or exchange of the stock of such foreign corporation. The temporary regulations affect certain persons that transfer stock to a foreign corporation in a transaction described in section 304(a)(1), or certain persons that recognize gain under section 301(c)(3) in connection with the receipt of a distribution of property from a foreign corporation with respect to its stock. E:\FR\FM\10MRR1.SGM 10MRR1

Agencies

[Federal Register Volume 74, Number 45 (Tuesday, March 10, 2009)]
[Rules and Regulations]
[Page 10174]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-4997]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9444]
RIN 1545-BI42


Application of Section 367 to a Section 351 Exchange Resulting 
From a Transaction Described in Section 304(a)(1); Treatment of Gain 
Recognized Under Section 301(c)(3) for Purposes of Section 1248; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final and temporary regulations.

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SUMMARY: This document contains a correction to final and temporary 
regulations (TD 9444) that were published in the Federal Register on 
Wednesday, February 11, 2009, under sections 367(a), 367(b) and 1248(a) 
of the Internal Revenue Code. The final regulations under section 367 
revise existing final regulations and add cross-references. The final 
regulations under section 1248 update an effective/applicability date. 
The temporary regulations under section 367(a) and (b) revise existing 
final regulations concerning transfers of stock to a foreign 
corporation that are described in section 351 by reason of section 
304(a)(1). The temporary regulations under section 1248(a) provide 
that, for purposes of section 1248(a), gain recognized by a shareholder 
under section 301(c)(3) in connection with the receipt of a 
distribution of property from a foreign corporation with respect to its 
stock shall be treated as gain from the sale or exchange of the stock 
of such foreign corporation. The temporary regulations affect certain 
persons that transfer stock to a foreign corporation in a transaction 
described in section 304(a)(1), or certain persons that recognize gain 
under section 301(c)(3) in connection with the receipt of a 
distribution of property from a foreign corporation with respect to its 
stock.

DATES: This correction is effective March 10, 2009, and is applicable 
on February 11, 2009.

FOR FURTHER INFORMATION CONTACT: Sean W. Mullaney, (202) 622-3860 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations that are the subject of this 
document are under sections 367 and 1248 of the Internal Revenue Code.

Need for Correction

    As published Wednesday, February 11, 2009 (74 FR 6824), final and 
temporary regulations (TD 9444) contains an error that may prove to be 
misleading and is in need of clarification.

Correction of Publication

    Accordingly, the publication of the final and temporary regulations 
(TD 9444), which was the subject of FR Doc. E9-2835, is corrected as 
follows:
    On page 6825, column 2, in the preamble, under the paragraph 
heading ``A. Modified Application of Section 367(a) to Deemed Section 
351 Exchanges'', first paragraph of the column, fourth line from the 
bottom of the paragraph, the language ``recognized $100x gain under 
section'' is corrected to read ``recognize $100x gain under section''.

Guy Traynor,
Acting Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel, (Procedure and Administration).
 [FR Doc. E9-4997 Filed 3-9-09; 8:45 am]
BILLING CODE 4830-01-P
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