Gain Recognition Agreements With Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction, 10175 [E9-4998]
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Federal Register / Vol. 74, No. 45 / Tuesday, March 10, 2009 / Rules and Regulations
DATES: This correction is effective
March 10, 2009, and is applicable on
February 11, 2009.
DEPARTMENT OF THE TREASURY
FOR FURTHER INFORMATION CONTACT:
Sean W. Mullaney, (202) 622–3860 (not
a toll-free number).
26 CFR Part 1
SUPPLEMENTARY INFORMATION:
RIN 1545–BG09
Background
Gain Recognition Agreements With
Respect to Certain Transfers of Stock
or Securities by United States Persons
to Foreign Corporations; Correction
Internal Revenue Service
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
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendment.
This document contains a
correction to final regulations (TD 9446)
that were published in the Federal
Register on Wednesday, February 11,
2009 (74 FR 6952) under section 367(a)
of the Internal Revenue Code
concerning gain recognition agreements
filed by United States persons with
respect to transfers of stock or securities
to foreign corporations.
DATES: This correction is effective
March 10, 2009, and is applicable on
February 11, 2009.
FOR FURTHER INFORMATION CONTACT: S.
James Hawes, (202) 622–3860 (not a tollfree number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
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.
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
Background
The final regulations that are the
subject of this document are under
sections 338 and 367 of the Internal
Revenue Code.
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.367(a)–9T is
amended by revising the paragraph of
(b)(1) as follows:
■
§ 1.367(a)–9T Treatment of deemed
section 351 exchanges pursuant to section
304(a)(1) (temporary).
*
*
*
*
*
(b) * * *
(1) The gain realized by the United
States person with respect to the
transferred stock in connection with the
deemed section 351 exchange exceeds;
*
*
*
*
*
Guy Traynor,
Acting Chief, Publications and Regulations
Branch, Legal Processing Division, Associate
Chief Counsel, (Procedure and
Administration).
[FR Doc. E9–4995 Filed 3–9–09; 8:45 am]
BILLING CODE 4830–01–P
[TD 9446]
Need for Correction
As published, final regulations (TD
9446) 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 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 1.367(a)–8 is amended
by revising paragraph (k)(3) to read as
follows:
■
§ 1.367(a)–8 Gain recognition agreement
requirements.
*
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10175
(k) * * *
(3) * * * A disposition of the
transferred stock or securities pursuant
to an exchange to which section 351,
354 (but only in a reorganization
described in section 368(a)(1)(B)), or 721
applies, shall not constitute a triggering
event if the U.S. transferor enters in to
a new gain recognition agreement that
provides that the dispositions described
in paragraphs (k)(3)(i) and (ii) of this
section shall constitute triggering events
for purposes of the new gain recognition
agreement.
*
*
*
*
*
Guy Traynor,
Acting Chief, Publications and Regulations
Branch, Legal Processing Division, Associate
Chief Counsel, (Procedure and
Administration).
[FR Doc. E9–4998 Filed 3–9–09; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF VETERANS
AFFAIRS
38 CFR Part 2
RIN 2900–AN09
Delegations of Authority: Regulation
Policy and Management
Department of Veterans Affairs.
Final rule.
AGENCY:
ACTION:
SUMMARY: This document amends the
Department of Veterans Affairs (VA)
regulations that delegate authority to
manage, direct, and coordinate VA’s
rulemaking activities to certain officials.
The amendments reflect the Secretary of
Veterans Affairs’ decisions to designate
the General Counsel as the Department’s
Regulatory Policy Officer and to transfer
the Office of Regulation Policy and
Management to the Office of the General
Counsel. These amendments are
intended to provide VA with a single
point of contact who can respond to the
Secretary’s rulemaking concerns.
DATES: Effective Date: March 10, 2009.
FOR FURTHER INFORMATION CONTACT:
Robert C. McFetridge, Director,
Regulation Policy and Management
(02REG), Office of the General Counsel,
U.S. Department of Veterans Affairs, 810
Vermont Avenue, NW., Washington, DC
20420, telephone (202) 461–4902. (This
is not a toll-free number.)
SUPPLEMENTARY INFORMATION: The Office
of Regulation Policy and Management
(ORPM) was established to provide
centralized management and
coordination for VA’s decentralized
rulemaking process. The head of ORPM
was designated as the Assistant to the
E:\FR\FM\10MRR1.SGM
10MRR1
]]>Agencies
[Federal Register Volume 74, Number 45 (Tuesday, March 10, 2009)]
[Rules and Regulations]
[Page 10175]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-4998]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9446]
RIN 1545-BG09
Gain Recognition Agreements With Respect to Certain Transfers of
Stock or Securities by United States Persons to Foreign Corporations;
Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendment.
-----------------------------------------------------------------------
SUMMARY: This document contains a correction to final regulations (TD
9446) that were published in the Federal Register on Wednesday,
February 11, 2009 (74 FR 6952) under section 367(a) of the Internal
Revenue Code concerning gain recognition agreements filed by United
States persons with respect to transfers of stock or securities to
foreign corporations.
DATES: This correction is effective March 10, 2009, and is applicable
on February 11, 2009.
FOR FURTHER INFORMATION CONTACT: S. James Hawes, (202) 622-3860 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the subject of this document are
under sections 338 and 367 of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9446) 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
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(a)-8 is amended by revising paragraph (k)(3) to
read as follows:
Sec. 1.367(a)-8 Gain recognition agreement requirements.
* * * * *
(k) * * *
(3) * * * A disposition of the transferred stock or securities
pursuant to an exchange to which section 351, 354 (but only in a
reorganization described in section 368(a)(1)(B)), or 721 applies,
shall not constitute a triggering event if the U.S. transferor enters
in to a new gain recognition agreement that provides that the
dispositions described in paragraphs (k)(3)(i) and (ii) of this section
shall constitute triggering events for purposes of the new gain
recognition agreement.
* * * * *
Guy Traynor,
Acting Chief, Publications and Regulations Branch, Legal Processing
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. E9-4998 Filed 3-9-09; 8:45 am]
BILLING CODE 4830-01-P
