Partnership Transactions Involving Equity Interests of a Partner; Correction, 38941 [2015-16673]
Download as PDF
<![CDATA[
Federal Register / Vol. 80, No. 130 / Wednesday, July 8, 2015 / Rules and Regulations
§ 1.337(d)–3T Gain recognition upon
certain partnership transactions involving a
partner’s stock (temporary).
*
*
*
*
*
(c) * * *
(2) * * * (i) In general. With respect
to a Corporate Partner, Stock of the
Corporate Partner includes the
Corporate Partner’s stock, or other
equity interests, including options,
warrants, and similar interests, in the
Corporate Partner or a corporation that
controls the Corporate Partner within
the meaning of section 304(c), except
that section 318(a)(1) and (3) shall not
apply. Stock of the Corporate Partner
also includes interests in any entity to
the extent that the value of the interest
is attributable to Stock of the Corporate
Partner.
(f) * * *
(2) * * *
(ii) Is not distributed to the Corporate
Partner or a corporation that controls
the Corporate Partner within the
meaning of section 304(c), except that
section 318(a)(1) and (3) shall not apply.
*
*
*
*
*
§ 1.732–1T
[Amended]
Par 3. Section 1.732–1T paragraph
(c)(5)(ii) is amended by removing the
word ‘‘Nothwithstanding’’ and adding
in its place the word
‘‘Notwithstanding’’.
■
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2015–16674 Filed 7–2–15; 4:15 pm]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9722]
RIN 1545–BM35
Partnership Transactions Involving
Equity Interests of a Partner;
Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Final and temporary
regulations; correction.
tkelley on DSK3SPTVN1PROD with RULES
AGENCY:
This document contains
corrections to final and temporary
regulations (TD 9722) that were
published in the Federal Register on
June 12, 2015 (80 FR 33402). The final
and temporary regulations prevent a
corporate partner from avoiding
corporate-level gain through
transactions with a partnership
involving equity interests of the partner.
DATES: This correction is effective on
July 2, 2015 and applicable beginning
June 12, 2015.
FOR FURTHER INFORMATION CONTACT:
Kevin I. Babitz at (202) 317–6852 (not a
toll free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
Background
The final and temporary regulations
(TD 9722) that are the subject of this
correction are under sections 311(b),
336(a), and 337(d) of the Internal
Revenue Code.
Need for Correction
As published, the final and temporary
regulations (TD 9722) contain errors that
may prove to be misleading and are in
need of clarification.
Correction of Publication
Accordingly, the final regulations (TD
9722), that are the subject of FR Doc.
2015–14405, are corrected as follows:
1. On page 33404, in the preamble,
the first column, the tenth and eleventh
lines from the top of the column, the
language ‘‘that controls (within the
meaning of section 304(c)) the Corporate
Partner.’’ is corrected to read ‘‘that
controls the Corporate Partner within
the meaning of section 304(c), except
that section 318(a)(1) and (3) shall not
apply (section 304(c) control).’’.
2. On page 33404, in the preamble,
the first column, the eighteenth through
the twentieth line from the top of the
first full paragraph, the language ‘‘that
controls the Corporate Partner within
the meaning of section 304(c) (section
304(c) control), whereas the’’ is
corrected to read ‘‘that possesses section
304(c) control of the Corporate Partner,
whereas the’’.
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 165
[Docket No. USCG–2015–0527]
Safety Zones; Recurring Events in
Captain of the Port Boston Zone
AGENCY:
Coast Guard, DHS.
Notice of enforcement of
regulation.
ACTION:
The Coast Guard will enforce
the safety zones in the Captain of the
Port Boston Zone on the specified dates
and times listed below. This action is
necessary to ensure the protection of the
maritime public and event participants
from the hazards associated with these
annual recurring events. Under the
provisions of our regulations, no person
or vessel, except for the safety vessels
assisting with the event may enter the
safety zones unless given permission
from the COTP or the designated onscene representative. The Coast Guard
may be assisted by other Federal, State,
or local law enforcement agencies in
enforcing this regulation.
SUMMARY:
The regulation for the safety
zones described in 33 CFR 165.118 will
be enforced on July 3, 2015 between
7:00 p.m. to 11:00 p.m., on July 4, 2015
from 9:00 p.m. to 11:00 p.m., on July 10,
2015 from 6:00 a.m. to 4:00 p.m., and on
July 11, 2015 from 8:30 a.m. to 10:30
a.m., as listed in the table located in the
Supplementary Information.
DATES:
If
you have questions on this document,
call or email Mr. Mark Cutter, Coast
Guard Sector Boston Waterways
Management Division, telephone 617–
223–4000, email Mark.E.Cutter@
uscg.mil.
FOR FURTHER INFORMATION CONTACT:
The Coast
Guard will enforce the safety zones
listed in 33 CFR 165.118 on the
specified dates and times as indicated in
Table 1 below.
SUPPLEMENTARY INFORMATION:
[FR Doc. 2015–16673 Filed 7–2–15; 4:15 pm]
BILLING CODE 4830–01–P
TABLE 1
7.1
City of Lynn 4th of July Celebration Fireworks ...............................
VerDate Sep<11>2014
18:08 Jul 07, 2015
Jkt 235001
PO 00000
Frm 00029
Fmt 4700
•
•
•
•
Event Type: Firework Display.
Sponsor: City of Lynn.
Date: July 3, 2015.
Time: 7:00 p.m. to 11:00 p.m.
Sfmt 4700
38941
E:\FR\FM\08JYR1.SGM
08JYR1
]]>Agencies
[Federal Register Volume 80, Number 130 (Wednesday, July 8, 2015)]
[Rules and Regulations]
[Page 38941]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-16673]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9722]
RIN 1545-BM35
Partnership Transactions Involving Equity Interests of a Partner;
Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final and temporary regulations; correction.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to final and temporary
regulations (TD 9722) that were published in the Federal Register on
June 12, 2015 (80 FR 33402). The final and temporary regulations
prevent a corporate partner from avoiding corporate-level gain through
transactions with a partnership involving equity interests of the
partner.
DATES: This correction is effective on July 2, 2015 and applicable
beginning June 12, 2015.
FOR FURTHER INFORMATION CONTACT: Kevin I. Babitz at (202) 317-6852 (not
a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9722) that are the subject
of this correction are under sections 311(b), 336(a), and 337(d) of the
Internal Revenue Code.
Need for Correction
As published, the final and temporary regulations (TD 9722) contain
errors that may prove to be misleading and are in need of
clarification.
Correction of Publication
Accordingly, the final regulations (TD 9722), that are the subject
of FR Doc. 2015-14405, are corrected as follows:
1. On page 33404, in the preamble, the first column, the tenth and
eleventh lines from the top of the column, the language ``that controls
(within the meaning of section 304(c)) the Corporate Partner.'' is
corrected to read ``that controls the Corporate Partner within the
meaning of section 304(c), except that section 318(a)(1) and (3) shall
not apply (section 304(c) control).''.
2. On page 33404, in the preamble, the first column, the eighteenth
through the twentieth line from the top of the first full paragraph,
the language ``that controls the Corporate Partner within the meaning
of section 304(c) (section 304(c) control), whereas the'' is corrected
to read ``that possesses section 304(c) control of the Corporate
Partner, whereas the''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-16673 Filed 7-2-15; 4:15 pm]
BILLING CODE 4830-01-P
