Inversions and Related Transactions, 20588-20591 [2016-07299]
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20588
Federal Register / Vol. 81, No. 68 / Friday, April 8, 2016 / Proposed Rules
3094). In the Rules and Regulations
section of this issue of the Federal
Register, the Treasury Department and
the IRS are amending certain of the
temporary regulations in § 1.7874–4T.
Accordingly, the Treasury Department
and the IRS are issuing a notice of
proposed rulemaking in the Proposed
Rules section of this issue of the Federal
Register that proposes rules in § 1.7874–
4 by cross-reference to the amended
temporary regulations. This document
withdraws the previously proposed
regulations that are replaced by the
notice of proposed rulemaking in the
Proposed Rules section of this issue of
the Federal Register.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Partial Withdrawal of a Notice of
Proposed Rulemaking
Accordingly, under the authority of
26 U.S.C. 7805, § 1.367(b)–4(e), (f), and
(g) of the notice of proposed rulemaking
(REG–147636–08) published in the
Federal Register on February 11, 2009
(74 FR 6840) are withdrawn. Also,
under the authority of 26 U.S.C. 7805,
§ 1.7874–4(c)(1)(i), (c)(1)(ii)(B), (c)(2),
(d)(1)(i), (d)(1)(ii), (h), (i)(6), (i)(7)(iii)(C),
(i)(7)(iv), (j)(7), (j)(8), and (k)(1), as well
as paragraph (ii) of Example 1,
paragraph (ii) of Example 2, and
Example 3 through Example 8 of
§ 1.7874–4(j), of the notice of proposed
rulemaking (REG–121534–12) published
in the Federal Register on January 17,
2014 (79 FR 3145) are withdrawn.
John Dalrymple,
Deputy Commissioner for Services and
Enforcement.
[FR Doc. 2016–07295 Filed 4–4–16; 5:00 pm]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–135734–14]
RIN 1545–BM45
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Inversions and Related Transactions
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking
by cross-reference to temporary
regulation.
AGENCY:
The Department of Treasury
(Treasury Department) and the IRS are
issuing temporary regulations that
address transactions that are structured
SUMMARY:
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to avoid the purposes of sections 7874
and 367 of the Internal Revenue Code
(the Code) and certain post-inversion
tax avoidance transactions in the Rules
and Regulations section of this issue of
the Federal Register. The temporary
regulations affect certain domestic
corporations and domestic partnerships
whose assets are directly or indirectly
acquired by a foreign corporation and
certain persons related to such domestic
corporations and domestic partnerships.
The text of the temporary regulations
also serves as the text of these proposed
regulations.
DATES: Written or electronic comments
and requests for a public hearing must
be received by July 7, 2016.
ADDRESSES: Send submissions to:
CC:PA:LPD:PR (REG–135734–14), room
5203, Internal Revenue Service, P.O.
Box 7604, Ben Franklin Station,
Washington, DC 20224. Submissions
may be hand-delivered Monday through
Friday between the hours of 8 a.m. and
4 p.m. to CC:PA:LPD:PR (REG–135734–
14), Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue NW.,
Washington, DC 20224, or sent
electronically via the Federal
eRulemaking Portal at https://
www.regulations.gov (IRS REG–135734–
14).
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations
under sections 304, 367, and 7874,
Shane M. McCarrick or David A. Levine,
(202) 317–6937; concerning the
proposed regulations under sections 956
and 7701(l), Rose E. Jenkins, (202) 317–
6934 (not toll-free numbers); concerning
submissions of comments or requests for
a public hearing, Regina Johnson, (202)
317–5177 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
The temporary regulations in the
Rules and Regulations section of this
issue of the Federal Register contain
regulations under sections 304, 367,
954, 956, 7701(l), and 7874 of the
Internal Revenue Code (Code) that
address transactions that are structured
to avoid the purposes of sections 7874
and 367 of the Internal Revenue Code
(the Code) and certain post-inversion
tax avoidance transactions. The text of
the temporary regulations also serves as
the text of the proposed regulations
herein. The preamble to the temporary
regulations explains the temporary
regulations and the corresponding
proposed regulations.
Special Analyses
Certain IRS regulations, including this
one, are exempt from the requirements
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of Executive Order 12866, as
supplemented and reaffirmed by
Executive Order 13563. Therefore, a
regulatory assessment is not required. It
has also been determined that section
553(b) of the Administrative Procedure
Act (5 U.S.C. Chapter 5) does not apply
to these regulations, and because the
regulations do not impose a collection
of information on small entities, the
Regulatory Flexibility Act (5 U.S.C.
chapter 6) does not apply. Pursuant to
section 7805(f), this notice of proposed
rulemaking has been submitted to the
Chief Counsel of Advocacy of the Small
Business Administration for comment
on its impact on small business.
Comments and Requests for Public
Hearing
Before these proposed regulations are
adopted as final regulations,
consideration will be given to any
comments that are submitted timely to
the IRS as prescribed in this preamble
under the ADDRESSES heading. Treasury
and the IRS request comments on all
aspects of the proposed rules. All
comments will be available at
www.regulations.gov or upon request. A
public hearing will be scheduled if
requested in writing by any person that
timely submits electronic or written
comments. If a public hearing is
scheduled, notice of the date, time, and
place for the public hearing will be
published in the Federal Register.
Drafting Information
The principal authors of these
proposed regulations are Rose E.
Jenkins, David A. Levine, and Shane M.
McCarrick of the Office of Associate
Chief Counsel (International). However,
other personnel from the Treasury
Department and the IRS participated in
their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 1 is
proposed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 is amended by adding and
revising entries in numerical order to
read in part as follows:
■
Authority: 26 U.S.C. 7805 * * *
Section 1.304–7 also issued under 26
U.S.C. 304(b)(5)(C).
Section 1.367(b)–4 also issued under 26
U.S.C. 367(a), 367(b), and 954(c)(6)(A).
Section 1.956–2 also issued under 26
U.S.C. 956(d) and 956(e).
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Section 1.7701(l)–4 also issued under 26
U.S.C. 7701(l) and 954(c)(6)(A).
Section 1.7874–2 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–4 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–6 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–7 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–8 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–9 also issued under 26
U.S.C. 7874(c)(6) and 7874(g).
Section 1.7874–10 also issued under 26
U.S.C. 7874(c)(4) and 7874(g).
Section 1.7874–11 also issued under 26
U.S.C. 7874(g).
Section 1.7874–12 also issued under 26
U.S.C. 7874(g).
Par. 2. Section 1.304–7 is added to
read as follows:
■
§ 1.304–7 Certain acquisitions by foreign
acquiring corporations.
[The text of proposed § 1.304–7 is the
same as the text of § 1.304–7T published
elsewhere in this issue of the Federal
Register.]
■ Par. 3. Section 1.367(a)–3 is amended
by revising paragraphs (c)(3)(iii)(C) and
(c)(11)(ii) to read as follows:
§ 1.367(a)–3 Treatment of transfers of
stock or securities to foreign corporations.
*
*
*
*
(c) * * *
(3) * * *
(iii) * * *
(C) [The text of the proposed
amendment to § 1.367(a)–3(c)(3)(iii)(C)
is the same as the text of § 1.367(a)–
3T(c)(3)(iii)(C) published elsewhere in
this issue of the Federal Register.]
*
*
*
*
*
(11) * * *
(ii) [The text of the proposed
amendment to § 1.367(a)–3(c)(11)(ii) is
the same as the text of § 1.367(a)–
3T(c)(11)(ii) published elsewhere in this
issue of the Federal Register.]
*
*
*
*
*
■ Par. 4. Section 1.367(b)–4 is amended
by revising paragraph (a), paragraph (b)
introductory text, and paragraphs
(b)(1)(i)(C), (d)(1), (e), (f), (g), and (h) to
read as follows:
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*
§ 1.367(b)–4 Acquisition of foreign
corporate stock or assets by a foreign
corporation in certain nonrecognition
transactions.
(a) [The text of the proposed
amendment to § 1.367(b)–4(a) is the
same as the text of § 1.367(b)–4T(a)
published elsewhere in this issue of the
Federal Register.]
(b) [The text of the proposed
amendment to the introductory text to
§ 1.367(b)–4(b) is the same as the
introductory text of § 1.367(b)–4T(b)
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published elsewhere in this issue of the
Federal Register.]
(1) * * *
(i) * * *
(C) [The text of the proposed
amendment to § 1.367(b)–4(b)(1)(i)(C) is
the same as the text of § 1.367(b)–
4T(b)(1)(i)(C) published elsewhere in
this issue of the Federal Register.]
*
*
*
*
*
(d) * * *
(1) [The text of the proposed
amendment to § 1.367(b)–4(d)(1) is the
same as the text of § 1.367(b)–4T(d)(1)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(e) [The text of the proposed
amendment to § 1.367(b)–4(e) is the
same as the text of § 1.367(b)–4T(e)
published elsewhere in this issue of the
Federal Register.]
(f) [The text of the proposed
amendment to § 1.367(b)–4(f) is the
same as the text of § 1.367(b)–4T(f)
published elsewhere in this issue of the
Federal Register.]
(g) [The text of the proposed
amendment to § 1.367(b)–4(g) is the
same as the text of § 1.367(b)–4T(g)
published elsewhere in this issue of the
Federal Register.]
(h) [The text of proposed § 1.367(b)–
4(h) is the same as the text of § 1.367(b)–
4T(h) published elsewhere in this issue
of the Federal Register.]
■ Par. 5. Section 1.956–2 is amended by
revising paragraphs (a)(4), (c)(5), (d)(2),
and (i) to read as follows:
§ 1.956–2
property.
Definition of United States
(a) * * *
(4) [The text of the proposed
amendment to § 1.956–2(a)(4) is the
same as the text of § 1.956–2T(a)(4)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(c) * * *
(5) [The text of the proposed
amendment to § 1.956–2(c)(5) is the
same as the text of § 1.956–2T(c)(5)
published elsewhere in this issue of the
Federal Register.]
(d) * * *
(2) [The text of the proposed
amendment to § 1.956–2(d)(2) is the
same as the text of § 1.956–2T(d)(2)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(i) [The text of the proposed
amendment to § 1.956–2(i) is the same
as the text of § 1.956–2T(i) published
elsewhere in this issue of the Federal
Register.]
■ Par. 6. Section 1.7701(l)–4 is added to
read as follows:
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§ 1.7701(l)–4 Rules regarding inversion
transactions.
[The text of proposed § 1.7701(l)–4 is
the same as the text of § 1.7701(l)–4T
published elsewhere in this issue of the
Federal Register.]
■ Par. 7. Section 1.7874–1 is amended
by revising paragraphs (c)(2)(iii), (f), and
(h)(2) to read as follows.
§ 1.7874–1
stock.
Disregard of affiliate-owned
*
*
*
*
*
(c) * * *
(2) * * *
(iii) [The text of the proposed
amendment to § 1.7874–1(c)(2)(iii) is the
same as the text of § 1.7874–1T(c)(2)(iii)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(f) [The text of the proposed
amendment to § 1.7874–1(f) is the same
as the text of § 1.7874–1T(f) published
elsewhere in this issue of the Federal
Register.]
*
*
*
*
*
(h) * * *
(2) [The text of the proposed
amendment to § 1.7874–1(h)(2) is the
same as the text of § 1.7874–1T(h)(2)
published elsewhere in this issue of the
Federal Register.]
■ Par. 8. Section 1.7874–2 is amended
by:
■ 1. Revising paragraphs (a), (b)(7),
(b)(8), (b)(9), (b)(10), (b)(11), (b)(12),
(b)(13), (c)(2), and (c)(4).
■ 2. Revising paragraph (f)(1)
introductory text.
■ 3. Revising paragraph (f)(1)(iv).
■ 4. Revising Example 21 of paragraph
(k)(2).
■ 5. Revising paragraph (l)(2).
The revisions read as follows:
§ 1.7874–2
Surrogate foreign corporation.
(a) [The text of the proposed
amendment to § 1.7874–2(a) is the same
as the text of § 1.7874–2T(a) published
elsewhere in this issue of the Federal
Register.]
(b) * * *
(7) [The text of the proposed
amendment to § 1.7874–2(b)(7) is the
same as the text of § 1.7874–2T(b)(7)
published elsewhere in this issue of the
Federal Register.]
(8) [The text of the proposed
amendment to § 1.7874–2(b)(8) is the
same as the text of § 1.7874–2T(b)(8)
published elsewhere in this issue of the
Federal Register.]
(9) [The text of the proposed
amendment to § 1.7874–2(b)(9) is the
same as the text of § 1.7874–2T(b)(9)
published elsewhere in this issue of the
Federal Register.]
(10) [The text of the proposed
amendment to § 1.7874–2(b)(10) is the
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same as the text of § 1.7874–2T(b)(10)
published elsewhere in this issue of the
Federal Register.]
(11) [The text of the proposed
amendment to § 1.7874–2(b)(11) is the
same as the text of § 1.7874–2T(b)(11)
published elsewhere in this issue of the
Federal Register.]
(12) [The text of the proposed
amendment to § 1.7874–2(b)(12) is the
same as the text of § 1.7874–2T(b)(12)
published elsewhere in this issue of the
Federal Register.]
(13) [The text of the proposed
amendment to § 1.7874–2(b)(13) is the
same as the text of § 1.7874–2T(b)(13)
published elsewhere in this issue of the
Federal Register.]
(c) * * *
(2) [The text of the proposed
amendment to § 1.7874–2(c)(2) is the
same as the text of § 1.7874–2T(c)(2)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(4) [The text of the proposed
amendment to § 1.7874–2(c)(4) is the
same as the text of § 1.7874–2T(c)(4)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(f) * * *
(1) [The proposed amendment to the
introductory text of § 1.7874–2(f)(1) is
the same as the introductory text of
§ 1.7874–2T(f)(1) published elsewhere
in this issue of the Federal Register.]
*
*
*
*
*
(iv) [The text of the proposed
amendment to § 1.7874–2(f)(1)(iv) is the
same as the text of § 1.7874–2T(f)(1)(iv)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(k) * * *
(2) * * *
Example 21. [The text of the proposed
amendment to Example 21 of § 1.7874–
2(k)(2) is the same as the text of
Example 21 of § 1.7874–2T(k)(2)
published elsewhere in this issue of the
Federal Register.]
(l) * * *
(2) [The text of the proposed
amendment to § 1.7874–2(l)(2) is the
same as the text of § 1.7874–2T(l)(2)
published elsewhere in this issue of the
Federal Register.]
■ Par. 9. Section 1.7874–3 is amended
by revising paragraphs (b)(4), (d)(10),
and (f)(2) to read as follows:
§ 1.7874–3
Substantial business activities.
*
*
*
*
*
(b) * * *
(4) [The text of the proposed
amendment to § 1.7874–3(b)(4) is the
same as the text of § 1.7874–3T(b)(4)
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published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(d) * * *
(10) [The text of the proposed
amendment to § 1.7874–3(d)(10) is the
same as the text of § 1.7874–3T(d)(10)
published elsewhere in this issue of the
Federal Register.]
(f) * * *
(2) [The text of the proposed
amendment to § 1.7874–3(f)(2) is the
same as the text of § 1.7874–3T(f)(2)
published elsewhere in this issue of the
Federal Register.]
■ Par. 10. Section 1.7874–4 is added to
read as follows.
§ 1.7874–4 Disregard of certain stock
related to the acquisition.
(a) through (c)(1) introductory text
[Reserved].
(i) [The text of proposed § 1.7874–
4(c)(1)(i) is the same as the text of
§ 1.7874–4T(c)(1)(i) as revised elsewhere
in this issue of the Federal Register.]
(ii) [Reserved].
(B) [The text of proposed § 1.7874–
4(c)(1)(ii)(B) is the same as the text of
§ 1.7874–4T(c)(1)(ii)(B) as revised
elsewhere in this issue of the Federal
Register.]
(2) [The text of proposed § 1.7874–
4(c)(2) is the same as the text of
§ 1.7874–4T(c)(2) as revised elsewhere
in this issue of the Federal Register.]
(d) introductory text through (d)(1)
introductory text [Reserved].
(i) [The text of proposed § 1.7874–
4(d)(1)(i) is the same as the text of
§ 1.7874–4T(d)(1)(i) published
elsewhere in this issue of the Federal
Register.]
(ii) [The text of proposed § 1.7874–
4(d)(1)(ii) is the same as the text of
§ 1.7874–4T(d)(1)(ii) as revised
elsewhere in this issue of the Federal
Register.]
(d)(2) through (g) [Reserved].
(h) [The text of proposed § 1.7874–
4(h) is the same as the text of § 1.7874–
4T(h) as revised elsewhere in this issue
of the Federal Register.]
(i) introductory text through (i)(5)
[Reserved].
(6) [The text of proposed § 1.7874–
4(i)(6) is the same as the text of
§ 1.7874–4T(i)(6) published elsewhere
in this issue of the Federal Register.]
(i)(7) introductory text through
(i)(7)(iii) introductory text [Reserved].
(C) [The text of proposed § 1.7874–
4(i)(7)(iii)(C) is the same as the text of
§ 1.7874–4T(i)(7)(iii)(C) as revised
elsewhere in this issue of the Federal
Register.]
(iv) [The text of proposed § 1.7874–
4(i)(7)(iv) is the same as the text of
§ 1.7874–4T(i)(7)(iv) published
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elsewhere in this issue of the Federal
Register.]
(j) introductory text through (j)(6)
[Reserved].
(7) [The text of proposed § 1.7874–
4(j)(7) is the same as the text of
§ 1.7874–4T(j)(7) as revised elsewhere in
this issue of the Federal Register.]
(8) [The text of proposed § 1.7874–
4(j)(8) is the same as the text of
§ 1.7874–4T(j)(8) as revised elsewhere in
this issue of the Federal Register.]
(9) [The text of proposed § 1.7874–
4(j)(9) is the same as the text of
§ 1.7874–4T(j)(9) published elsewhere
in this issue of the Federal Register.]
(10) [The text of proposed § 1.7874–
4(j)(10) is the same as the text of
§ 1.7874–4T(j)(10) published elsewhere
in this issue of the Federal Register.]
(11) [The text of proposed § 1.7874–
4(j)(11) is the same as the text of
§ 1.7874–4T(j)(11) published elsewhere
in this issue of the Federal Register.]
Example 1 introductory text through
Example 1 paragraph (i) [Reserved].
(ii) [The text of proposed paragraph
(ii) of Example 1 of § 1.7874–4(j) is the
same as the text of paragraph (ii) of
Example 1 of § 1.7874–4T(j) as revised
elsewhere in this issue of the Federal
Register.]
Example 2 introductory text through
Example 2 paragraph (i) [Reserved].
(ii) [The text of proposed paragraph
(ii) of Example 2 of § 1.7874–4(j) is the
same as the text of paragraph (ii) of
Example 2 of § 1.7874–4T(j) as revised
elsewhere in this issue of the Federal
Register.]
Example 3. [The text of proposed
Example 3 of § 1.7874–4(j) is the same
as the text of Example 3 of § 1.7874–
4T(j) published elsewhere in this issue
of the Federal Register.]
Example 4. [The text of proposed
Example 4 of § 1.7874–4(j) is the same
as the text of Example 4 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
Example 5. [The text of proposed
Example 5 of § 1.7874–4(j) is the same
as the text of Example 5 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
Example 6. [The text of proposed
Example 6 of § 1.7874–4(j) is the same
as the text of Example 6 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
Example 7. [The text of proposed
Example 7 of § 1.7874–4(j) is the same
as the text of Example 7 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
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Example 8. [The text of proposed
Example 8 of § 1.7874–4(j) is the same
as the text of Example 8 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
Example 9. [The text of proposed
Example 9 of § 1.7874–4(j) is the same
as the text of Example 9 of § 1.7874–
4T(j) as redesignated and revised
elsewhere in this issue of the Federal
Register.]
(k) introductory text [Reserved].
(1) [The text of proposed § 1.7874–
4(k)(1) is the same as the text of
§ 1.7874–4T(k)(1) published elsewhere
in this issue of the Federal Register.]
(k)(2) through (k)(3) [Reserved].
■ Par. 11. Section 1.7874–6 is added to
read as follows:
§ 1.7874–6 Stock transferred by members
of the EAG.
[The text of proposed § 1.7874–6 is
the same as the text of § 1.7874–6T
published elsewhere in this issue of the
Federal Register.]
■ Par. 12. Section 1.7874–7 is added to
read as follows:
§ 1.7874–8 Disregard of certain stock
attributable to multiple domestic entity
acquisitions.
[The text of proposed § 1.7874–8 is
the same as the text of § 1.7874–8T
published elsewhere in this issue of the
Federal Register.]
■ Par. 14. Section 1.7874–9 is added to
read as follows:
§ 1.7874–9 Disregard of certain stock in
third-country transactions.
[The text of proposed § 1.7874–9 is
the same as the text of § 1.7874–9T
published elsewhere in this issue of the
Federal Register.]
■ Par. 15. Section 1.7874–10 is added to
read as follows:
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§ 1.7874–10 Disregard of certain
distributions.
[The text of proposed § 1.7874–10 is
the same as the text of § 1.7874–10T
published elsewhere in this issue of the
Federal Register.]
■ Par. 16. Section 1.7874–11 is added to
read as follows:
Rules regarding inversion
[The text of proposed § 1.7874–11 is
the same as the text of § 1.7874–11T
18:31 Apr 07, 2016
Jkt 238001
Definitions.
[The text of proposed § 1.7874–12 is
the same as the text of § 1.7874–12T
published elsewhere in this issue of the
Federal Register.]
John Dalrymple,
Deputy Commissioner for Services and
Enforcement.
[FR Doc. 2016–07299 Filed 4–4–16; 5:00 pm]
BILLING CODE 4830–01–P
DEPARTMENT OF THE INTERIOR
Office of Surface Mining Reclamation
and Enforcement
30 CFR Part 943
[SATS No. TX–067–FOR; Docket ID: OSM–
2016–0001; S1D1S SS08011000 SX064A000
167S180110; S2D2S SS08011000
SX064A000 16XS501520]
Office of Surface Mining
Reclamation and Enforcement, Interior.
ACTION: Proposed rule; public comment
period and opportunity for public
hearing on proposed amendment.
AGENCY:
[The text of proposed § 1.7874–7 is
the same as the text of § 1.7874–7T
published elsewhere in this issue of the
Federal Register.]
■ Par. 13. Section 1.7874–8 is added to
read as follows:
VerDate Sep<11>2014
§ 1.7874–12
Texas Regulatory Program
§ 1.7874–7 Disregard of certain stock
attributable to passive assets.
§ 1.7874–11
gain.
published elsewhere in this issue of the
Federal Register.]
■ Par. 17. Section 1.7874–12 is added to
read as follows:
We, the Office of Surface
Mining Reclamation and Enforcement
(OSMRE), are announcing receipt of a
proposed amendment to the Texas
regulatory program (Texas program)
under the Surface Mining Control and
Reclamation Act of 1977 (SMCRA or the
Act). Texas proposes revisions to its
regulations regarding annual permit
fees. Texas intends to revise its program
to improve operational efficiency.
This document gives the times and
locations that the Texas program and
proposed amendment to that program
are available for your inspection, the
comment period during which you may
submit written comments on the
amendment, and the procedures that we
will follow for the public hearing, if one
is requested.
DATES: We will accept written
comments on this amendment until 4:00
p.m., c.t., May 9, 2016. If requested, we
will hold a public hearing on the
amendment on May 3, 2016. We will
accept requests to speak at a hearing
until 4:00 p.m., c.t. on April 25, 2016.
ADDRESSES: You may submit comments,
identified by SATS No. TX–067–FOR,
by any of the following methods:
• Mail/Hand Delivery: Director, Tulsa
Field Office, Office of Surface Mining
SUMMARY:
PO 00000
Frm 00017
Fmt 4702
Sfmt 4702
20591
Reclamation and Enforcement, 1645
South 101st East Avenue, Suite 145,
Tulsa, Oklahoma 74128–4629.
• Fax: (918) 581–6419.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
Instructions: All submissions received
must include the agency name and
docket number for this rulemaking. For
detailed instructions on submitting
comments and additional information
on the rulemaking process, see the
‘‘Public Comment Procedures’’ heading
of the SUPPLEMENTARY INFORMATION
section of this document.
Docket: For access to the docket to
review copies of the Texas program, this
amendment, a listing of any scheduled
public hearings, and all written
comments received in response to this
document, you must go to the address
listed below during normal business
hours, Monday through Friday,
excluding holidays. You may receive
one free copy of the amendment by
contacting OSMRE’s Tulsa Field Office
or going to www.regulations.gov.
Director: Tulsa Field Office, Office of
Surface Mining Reclamation and
Enforcement, 1645 South 101st East
Avenue, Suite 145, Tulsa, Oklahoma
74128–4629, Telephone: (918) 581–
6430.
In addition, you may review a copy of
the amendment during regular business
hours at the following location: Surface
Mining and Reclamation Division,
Railroad Commission of Texas, 1701
North Congress Avenue, Capitol Station,
P.O. Box 12967, Austin, Texas 78711–
2967, Telephone: (512) 463–6900.
FOR FURTHER INFORMATION CONTACT:
Director, Tulsa Field Office. Telephone:
(918) 581–6430. Email: Debbie Dale at
ddale@osmre.gov.
SUPPLEMENTARY INFORMATION:
I. Background on the Texas Program
II. Description of the Proposed Amendment
III. Public Comment Procedures
IV. Procedural Determinations
I. Background on the Texas Program
Section 503(a) of the Act permits a
State to assume primacy for the
regulation of surface coal mining and
reclamation operations on non-Federal
and non-Indian lands within its borders
by demonstrating that its program
includes, among other things, ‘‘a State
law which provides for the regulation of
surface coal mining and reclamation
operations in accordance with the
requirements of this Act . . .; and rules
and regulations consistent with
regulations issued by the Secretary
pursuant to this Act.’’ See 30 U.S.C.
1253(a)(1) and (7). On the basis of these
E:\FR\FM\08APP1.SGM
08APP1
]]>Agencies
[Federal Register Volume 81, Number 68 (Friday, April 8, 2016)]
[Proposed Rules]
[Pages 20588-20591]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-07299]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-135734-14]
RIN 1545-BM45
Inversions and Related Transactions
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking by cross-reference to temporary
regulation.
-----------------------------------------------------------------------
SUMMARY: The Department of Treasury (Treasury Department) and the IRS
are issuing temporary regulations that address transactions that are
structured to avoid the purposes of sections 7874 and 367 of the
Internal Revenue Code (the Code) and certain post-inversion tax
avoidance transactions in the Rules and Regulations section of this
issue of the Federal Register. The temporary regulations affect certain
domestic corporations and domestic partnerships whose assets are
directly or indirectly acquired by a foreign corporation and certain
persons related to such domestic corporations and domestic
partnerships. The text of the temporary regulations also serves as the
text of these proposed regulations.
DATES: Written or electronic comments and requests for a public hearing
must be received by July 7, 2016.
ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-135734-14), room
5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20224. Submissions may be hand-delivered Monday through
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
135734-14), Courier's Desk, Internal Revenue Service, 1111 Constitution
Avenue NW., Washington, DC 20224, or sent electronically via the
Federal eRulemaking Portal at https://www.regulations.gov (IRS REG-
135734-14).
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations
under sections 304, 367, and 7874, Shane M. McCarrick or David A.
Levine, (202) 317-6937; concerning the proposed regulations under
sections 956 and 7701(l), Rose E. Jenkins, (202) 317-6934 (not toll-
free numbers); concerning submissions of comments or requests for a
public hearing, Regina Johnson, (202) 317-5177 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
The temporary regulations in the Rules and Regulations section of
this issue of the Federal Register contain regulations under sections
304, 367, 954, 956, 7701(l), and 7874 of the Internal Revenue Code
(Code) that address transactions that are structured to avoid the
purposes of sections 7874 and 367 of the Internal Revenue Code (the
Code) and certain post-inversion tax avoidance transactions. The text
of the temporary regulations also serves as the text of the proposed
regulations herein. The preamble to the temporary regulations explains
the temporary regulations and the corresponding proposed regulations.
Special Analyses
Certain IRS regulations, including this one, are exempt from the
requirements of Executive Order 12866, as supplemented and reaffirmed
by Executive Order 13563. Therefore, a regulatory assessment is not
required. It has also been determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C. Chapter 5) does not apply to
these regulations, and because the regulations do not impose a
collection of information on small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f),
this notice of proposed rulemaking has been submitted to the Chief
Counsel of Advocacy of the Small Business Administration for comment on
its impact on small business.
Comments and Requests for Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any comments that are submitted timely
to the IRS as prescribed in this preamble under the ADDRESSES heading.
Treasury and the IRS request comments on all aspects of the proposed
rules. All comments will be available at www.regulations.gov or upon
request. A public hearing will be scheduled if requested in writing by
any person that timely submits electronic or written comments. If a
public hearing is scheduled, notice of the date, time, and place for
the public hearing will be published in the Federal Register.
Drafting Information
The principal authors of these proposed regulations are Rose E.
Jenkins, David A. Levine, and Shane M. McCarrick of the Office of
Associate Chief Counsel (International). However, other personnel from
the Treasury Department and the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 is amended by adding and
revising entries in numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.304-7 also issued under 26 U.S.C. 304(b)(5)(C).
Section 1.367(b)-4 also issued under 26 U.S.C. 367(a), 367(b),
and 954(c)(6)(A).
Section 1.956-2 also issued under 26 U.S.C. 956(d) and 956(e).
[[Page 20589]]
Section 1.7701(l)-4 also issued under 26 U.S.C. 7701(l) and
954(c)(6)(A).
Section 1.7874-2 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-4 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-6 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-7 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-8 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-9 also issued under 26 U.S.C. 7874(c)(6) and
7874(g).
Section 1.7874-10 also issued under 26 U.S.C. 7874(c)(4) and
7874(g).
Section 1.7874-11 also issued under 26 U.S.C. 7874(g).
Section 1.7874-12 also issued under 26 U.S.C. 7874(g).
0
Par. 2. Section 1.304-7 is added to read as follows:
Sec. 1.304-7 Certain acquisitions by foreign acquiring corporations.
[The text of proposed Sec. 1.304-7 is the same as the text of
Sec. 1.304-7T published elsewhere in this issue of the Federal
Register.]
0
Par. 3. Section 1.367(a)-3 is amended by revising paragraphs
(c)(3)(iii)(C) and (c)(11)(ii) to read as follows:
Sec. 1.367(a)-3 Treatment of transfers of stock or securities to
foreign corporations.
* * * * *
(c) * * *
(3) * * *
(iii) * * *
(C) [The text of the proposed amendment to Sec. 1.367(a)-
3(c)(3)(iii)(C) is the same as the text of Sec. 1.367(a)-
3T(c)(3)(iii)(C) published elsewhere in this issue of the Federal
Register.]
* * * * *
(11) * * *
(ii) [The text of the proposed amendment to Sec. 1.367(a)-
3(c)(11)(ii) is the same as the text of Sec. 1.367(a)-3T(c)(11)(ii)
published elsewhere in this issue of the Federal Register.]
* * * * *
0
Par. 4. Section 1.367(b)-4 is amended by revising paragraph (a),
paragraph (b) introductory text, and paragraphs (b)(1)(i)(C), (d)(1),
(e), (f), (g), and (h) to read as follows:
Sec. 1.367(b)-4 Acquisition of foreign corporate stock or assets by a
foreign corporation in certain nonrecognition transactions.
(a) [The text of the proposed amendment to Sec. 1.367(b)-4(a) is
the same as the text of Sec. 1.367(b)-4T(a) published elsewhere in
this issue of the Federal Register.]
(b) [The text of the proposed amendment to the introductory text to
Sec. 1.367(b)-4(b) is the same as the introductory text of Sec.
1.367(b)-4T(b) published elsewhere in this issue of the Federal
Register.]
(1) * * *
(i) * * *
(C) [The text of the proposed amendment to Sec. 1.367(b)-
4(b)(1)(i)(C) is the same as the text of Sec. 1.367(b)-4T(b)(1)(i)(C)
published elsewhere in this issue of the Federal Register.]
* * * * *
(d) * * *
(1) [The text of the proposed amendment to Sec. 1.367(b)-4(d)(1)
is the same as the text of Sec. 1.367(b)-4T(d)(1) published elsewhere
in this issue of the Federal Register.]
* * * * *
(e) [The text of the proposed amendment to Sec. 1.367(b)-4(e) is
the same as the text of Sec. 1.367(b)-4T(e) published elsewhere in
this issue of the Federal Register.]
(f) [The text of the proposed amendment to Sec. 1.367(b)-4(f) is
the same as the text of Sec. 1.367(b)-4T(f) published elsewhere in
this issue of the Federal Register.]
(g) [The text of the proposed amendment to Sec. 1.367(b)-4(g) is
the same as the text of Sec. 1.367(b)-4T(g) published elsewhere in
this issue of the Federal Register.]
(h) [The text of proposed Sec. 1.367(b)-4(h) is the same as the
text of Sec. 1.367(b)-4T(h) published elsewhere in this issue of the
Federal Register.]
0
Par. 5. Section 1.956-2 is amended by revising paragraphs (a)(4),
(c)(5), (d)(2), and (i) to read as follows:
Sec. 1.956-2 Definition of United States property.
(a) * * *
(4) [The text of the proposed amendment to Sec. 1.956-2(a)(4) is
the same as the text of Sec. 1.956-2T(a)(4) published elsewhere in
this issue of the Federal Register.]
* * * * *
(c) * * *
(5) [The text of the proposed amendment to Sec. 1.956-2(c)(5) is
the same as the text of Sec. 1.956-2T(c)(5) published elsewhere in
this issue of the Federal Register.]
(d) * * *
(2) [The text of the proposed amendment to Sec. 1.956-2(d)(2) is
the same as the text of Sec. 1.956-2T(d)(2) published elsewhere in
this issue of the Federal Register.]
* * * * *
(i) [The text of the proposed amendment to Sec. 1.956-2(i) is the
same as the text of Sec. 1.956-2T(i) published elsewhere in this issue
of the Federal Register.]
0
Par. 6. Section 1.7701(l)-4 is added to read as follows:
Sec. 1.7701(l)-4 Rules regarding inversion transactions.
[The text of proposed Sec. 1.7701(l)-4 is the same as the text of
Sec. 1.7701(l)-4T published elsewhere in this issue of the Federal
Register.]
0
Par. 7. Section 1.7874-1 is amended by revising paragraphs (c)(2)(iii),
(f), and (h)(2) to read as follows.
Sec. 1.7874-1 Disregard of affiliate-owned stock.
* * * * *
(c) * * *
(2) * * *
(iii) [The text of the proposed amendment to Sec. 1.7874-
1(c)(2)(iii) is the same as the text of Sec. 1.7874-1T(c)(2)(iii)
published elsewhere in this issue of the Federal Register.]
* * * * *
(f) [The text of the proposed amendment to Sec. 1.7874-1(f) is the
same as the text of Sec. 1.7874-1T(f) published elsewhere in this
issue of the Federal Register.]
* * * * *
(h) * * *
(2) [The text of the proposed amendment to Sec. 1.7874-1(h)(2) is
the same as the text of Sec. 1.7874-1T(h)(2) published elsewhere in
this issue of the Federal Register.]
0
Par. 8. Section 1.7874-2 is amended by:
0
1. Revising paragraphs (a), (b)(7), (b)(8), (b)(9), (b)(10), (b)(11),
(b)(12), (b)(13), (c)(2), and (c)(4).
0
2. Revising paragraph (f)(1) introductory text.
0
3. Revising paragraph (f)(1)(iv).
0
4. Revising Example 21 of paragraph (k)(2).
0
5. Revising paragraph (l)(2).
The revisions read as follows:
Sec. 1.7874-2 Surrogate foreign corporation.
(a) [The text of the proposed amendment to Sec. 1.7874-2(a) is the
same as the text of Sec. 1.7874-2T(a) published elsewhere in this
issue of the Federal Register.]
(b) * * *
(7) [The text of the proposed amendment to Sec. 1.7874-2(b)(7) is
the same as the text of Sec. 1.7874-2T(b)(7) published elsewhere in
this issue of the Federal Register.]
(8) [The text of the proposed amendment to Sec. 1.7874-2(b)(8) is
the same as the text of Sec. 1.7874-2T(b)(8) published elsewhere in
this issue of the Federal Register.]
(9) [The text of the proposed amendment to Sec. 1.7874-2(b)(9) is
the same as the text of Sec. 1.7874-2T(b)(9) published elsewhere in
this issue of the Federal Register.]
(10) [The text of the proposed amendment to Sec. 1.7874-2(b)(10)
is the
[[Page 20590]]
same as the text of Sec. 1.7874-2T(b)(10) published elsewhere in this
issue of the Federal Register.]
(11) [The text of the proposed amendment to Sec. 1.7874-2(b)(11)
is the same as the text of Sec. 1.7874-2T(b)(11) published elsewhere
in this issue of the Federal Register.]
(12) [The text of the proposed amendment to Sec. 1.7874-2(b)(12)
is the same as the text of Sec. 1.7874-2T(b)(12) published elsewhere
in this issue of the Federal Register.]
(13) [The text of the proposed amendment to Sec. 1.7874-2(b)(13)
is the same as the text of Sec. 1.7874-2T(b)(13) published elsewhere
in this issue of the Federal Register.]
(c) * * *
(2) [The text of the proposed amendment to Sec. 1.7874-2(c)(2) is
the same as the text of Sec. 1.7874-2T(c)(2) published elsewhere in
this issue of the Federal Register.]
* * * * *
(4) [The text of the proposed amendment to Sec. 1.7874-2(c)(4) is
the same as the text of Sec. 1.7874-2T(c)(4) published elsewhere in
this issue of the Federal Register.]
* * * * *
(f) * * *
(1) [The proposed amendment to the introductory text of Sec.
1.7874-2(f)(1) is the same as the introductory text of Sec. 1.7874-
2T(f)(1) published elsewhere in this issue of the Federal Register.]
* * * * *
(iv) [The text of the proposed amendment to Sec. 1.7874-
2(f)(1)(iv) is the same as the text of Sec. 1.7874-2T(f)(1)(iv)
published elsewhere in this issue of the Federal Register.]
* * * * *
(k) * * *
(2) * * *
Example 21. [The text of the proposed amendment to Example 21 of
Sec. 1.7874-2(k)(2) is the same as the text of Example 21 of Sec.
1.7874-2T(k)(2) published elsewhere in this issue of the Federal
Register.]
(l) * * *
(2) [The text of the proposed amendment to Sec. 1.7874-2(l)(2) is
the same as the text of Sec. 1.7874-2T(l)(2) published elsewhere in
this issue of the Federal Register.]
0
Par. 9. Section 1.7874-3 is amended by revising paragraphs (b)(4),
(d)(10), and (f)(2) to read as follows:
Sec. 1.7874-3 Substantial business activities.
* * * * *
(b) * * *
(4) [The text of the proposed amendment to Sec. 1.7874-3(b)(4) is
the same as the text of Sec. 1.7874-3T(b)(4) published elsewhere in
this issue of the Federal Register.]
* * * * *
(d) * * *
(10) [The text of the proposed amendment to Sec. 1.7874-3(d)(10)
is the same as the text of Sec. 1.7874-3T(d)(10) published elsewhere
in this issue of the Federal Register.]
(f) * * *
(2) [The text of the proposed amendment to Sec. 1.7874-3(f)(2) is
the same as the text of Sec. 1.7874-3T(f)(2) published elsewhere in
this issue of the Federal Register.]
0
Par. 10. Section 1.7874-4 is added to read as follows.
Sec. 1.7874-4 Disregard of certain stock related to the acquisition.
(a) through (c)(1) introductory text [Reserved].
(i) [The text of proposed Sec. 1.7874-4(c)(1)(i) is the same as
the text of Sec. 1.7874-4T(c)(1)(i) as revised elsewhere in this issue
of the Federal Register.]
(ii) [Reserved].
(B) [The text of proposed Sec. 1.7874-4(c)(1)(ii)(B) is the same
as the text of Sec. 1.7874-4T(c)(1)(ii)(B) as revised elsewhere in
this issue of the Federal Register.]
(2) [The text of proposed Sec. 1.7874-4(c)(2) is the same as the
text of Sec. 1.7874-4T(c)(2) as revised elsewhere in this issue of the
Federal Register.]
(d) introductory text through (d)(1) introductory text [Reserved].
(i) [The text of proposed Sec. 1.7874-4(d)(1)(i) is the same as
the text of Sec. 1.7874-4T(d)(1)(i) published elsewhere in this issue
of the Federal Register.]
(ii) [The text of proposed Sec. 1.7874-4(d)(1)(ii) is the same as
the text of Sec. 1.7874-4T(d)(1)(ii) as revised elsewhere in this
issue of the Federal Register.]
(d)(2) through (g) [Reserved].
(h) [The text of proposed Sec. 1.7874-4(h) is the same as the text
of Sec. 1.7874-4T(h) as revised elsewhere in this issue of the Federal
Register.]
(i) introductory text through (i)(5) [Reserved].
(6) [The text of proposed Sec. 1.7874-4(i)(6) is the same as the
text of Sec. 1.7874-4T(i)(6) published elsewhere in this issue of the
Federal Register.]
(i)(7) introductory text through (i)(7)(iii) introductory text
[Reserved].
(C) [The text of proposed Sec. 1.7874-4(i)(7)(iii)(C) is the same
as the text of Sec. 1.7874-4T(i)(7)(iii)(C) as revised elsewhere in
this issue of the Federal Register.]
(iv) [The text of proposed Sec. 1.7874-4(i)(7)(iv) is the same as
the text of Sec. 1.7874-4T(i)(7)(iv) published elsewhere in this issue
of the Federal Register.]
(j) introductory text through (j)(6) [Reserved].
(7) [The text of proposed Sec. 1.7874-4(j)(7) is the same as the
text of Sec. 1.7874-4T(j)(7) as revised elsewhere in this issue of the
Federal Register.]
(8) [The text of proposed Sec. 1.7874-4(j)(8) is the same as the
text of Sec. 1.7874-4T(j)(8) as revised elsewhere in this issue of the
Federal Register.]
(9) [The text of proposed Sec. 1.7874-4(j)(9) is the same as the
text of Sec. 1.7874-4T(j)(9) published elsewhere in this issue of the
Federal Register.]
(10) [The text of proposed Sec. 1.7874-4(j)(10) is the same as the
text of Sec. 1.7874-4T(j)(10) published elsewhere in this issue of the
Federal Register.]
(11) [The text of proposed Sec. 1.7874-4(j)(11) is the same as the
text of Sec. 1.7874-4T(j)(11) published elsewhere in this issue of the
Federal Register.]
Example 1 introductory text through Example 1 paragraph (i)
[Reserved].
(ii) [The text of proposed paragraph (ii) of Example 1 of Sec.
1.7874-4(j) is the same as the text of paragraph (ii) of Example 1 of
Sec. 1.7874-4T(j) as revised elsewhere in this issue of the Federal
Register.]
Example 2 introductory text through Example 2 paragraph (i)
[Reserved].
(ii) [The text of proposed paragraph (ii) of Example 2 of Sec.
1.7874-4(j) is the same as the text of paragraph (ii) of Example 2 of
Sec. 1.7874-4T(j) as revised elsewhere in this issue of the Federal
Register.]
Example 3. [The text of proposed Example 3 of Sec. 1.7874-4(j) is
the same as the text of Example 3 of Sec. 1.7874-4T(j) published
elsewhere in this issue of the Federal Register.]
Example 4. [The text of proposed Example 4 of Sec. 1.7874-4(j) is
the same as the text of Example 4 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
Example 5. [The text of proposed Example 5 of Sec. 1.7874-4(j) is
the same as the text of Example 5 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
Example 6. [The text of proposed Example 6 of Sec. 1.7874-4(j) is
the same as the text of Example 6 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
Example 7. [The text of proposed Example 7 of Sec. 1.7874-4(j) is
the same as the text of Example 7 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
[[Page 20591]]
Example 8. [The text of proposed Example 8 of Sec. 1.7874-4(j) is
the same as the text of Example 8 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
Example 9. [The text of proposed Example 9 of Sec. 1.7874-4(j) is
the same as the text of Example 9 of Sec. 1.7874-4T(j) as redesignated
and revised elsewhere in this issue of the Federal Register.]
(k) introductory text [Reserved].
(1) [The text of proposed Sec. 1.7874-4(k)(1) is the same as the
text of Sec. 1.7874-4T(k)(1) published elsewhere in this issue of the
Federal Register.]
(k)(2) through (k)(3) [Reserved].
0
Par. 11. Section 1.7874-6 is added to read as follows:
Sec. 1.7874-6 Stock transferred by members of the EAG.
[The text of proposed Sec. 1.7874-6 is the same as the text of
Sec. 1.7874-6T published elsewhere in this issue of the Federal
Register.]
0
Par. 12. Section 1.7874-7 is added to read as follows:
Sec. 1.7874-7 Disregard of certain stock attributable to passive
assets.
[The text of proposed Sec. 1.7874-7 is the same as the text of
Sec. 1.7874-7T published elsewhere in this issue of the Federal
Register.]
0
Par. 13. Section 1.7874-8 is added to read as follows:
Sec. 1.7874-8 Disregard of certain stock attributable to multiple
domestic entity acquisitions.
[The text of proposed Sec. 1.7874-8 is the same as the text of
Sec. 1.7874-8T published elsewhere in this issue of the Federal
Register.]
0
Par. 14. Section 1.7874-9 is added to read as follows:
Sec. 1.7874-9 Disregard of certain stock in third-country
transactions.
[The text of proposed Sec. 1.7874-9 is the same as the text of
Sec. 1.7874-9T published elsewhere in this issue of the Federal
Register.]
0
Par. 15. Section 1.7874-10 is added to read as follows:
Sec. 1.7874-10 Disregard of certain distributions.
[The text of proposed Sec. 1.7874-10 is the same as the text of
Sec. 1.7874-10T published elsewhere in this issue of the Federal
Register.]
0
Par. 16. Section 1.7874-11 is added to read as follows:
Sec. 1.7874-11 Rules regarding inversion gain.
[The text of proposed Sec. 1.7874-11 is the same as the text of
Sec. 1.7874-11T published elsewhere in this issue of the Federal
Register.]
0
Par. 17. Section 1.7874-12 is added to read as follows:
Sec. 1.7874-12 Definitions.
[The text of proposed Sec. 1.7874-12 is the same as the text of
Sec. 1.7874-12T published elsewhere in this issue of the Federal
Register.]
John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2016-07299 Filed 4-4-16; 5:00 pm]
BILLING CODE 4830-01-P
