Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs], 36816-36818 [2016-13425]

Download as PDF 36816 Federal Register / Vol. 81, No. 110 / Wednesday, June 8, 2016 / Proposed Rules Availability of NPRMs An electronic copy of this document may be downloaded through the Internet at http://www.regulations.gov. Recently published rulemaking documents can also be accessed through the FAA’s Web page at http:// www.faa.gov/airports_airtraffic/air_ traffic/publications/airspace_ amendments/. You may review the public docket containing the proposal, any comments received and any final disposition in person in the Dockets Office (see ADDRESSES section for address and phone number) between 9:00 a.m. and 5:00 p.m., Monday through Friday, except Federal holidays. An informal docket may also be examined during normal business hours at the Central Service Center, Operation Support Group, 10101 Hillwood Parkway, Fort Worth, TX 76177. Persons interested in being placed on a mailing list for future NPRMs should contact the FAA’s Office of Rulemaking (202) 267–9677, to request a copy of Advisory Circular No. 11–2A, Notice of Proposed Rulemaking Distribution System, which describes the application procedure. Availability and Summary of Documents Proposed for Incorporation by Reference This document would amend FAA Order 7400.9Z, Airspace Designations and Reporting Points, dated August 6, 2015, and effective September 15, 2015. FAA Order 7400.9Z is publicly available as listed in the ADDRESSES section of this document. FAA Order 7400.9Z lists Class A, B, C, D, and E airspace areas, air traffic service routes, and reporting points. ehiers on DSK5VPTVN1PROD with PROPOSALS The Proposal The FAA is proposing an amendment to Title 14, Code of Federal Regulations (14 CFR) Part 71 by establishing Class E airspace extending upward from 700 feet above the surface within an 6-mile radius of Lakota Municipal Airport, Lakota, ND, to accommodate new standard instrument approach procedures. Controlled airspace is needed for the safety and management of IFR operations at the airport. Class E airspace designations are published in Section 6005 of FAA Order 7400.9Z, dated August 6, 2015, and effective September 15, 2015, which is incorporated by reference in 14 CFR 71.1. The Class E airspace designation listed in this document will be published subsequently in the Order. VerDate Sep<11>2014 14:36 Jun 07, 2016 Jkt 238001 Regulatory Notices and Analyses The FAA has determined that this regulation only involves an established body of technical regulations for which frequent and routine amendments are necessary to keep them operationally current, is non-controversial and unlikely to result in adverse or negative comments. It, therefore: (1) Is not a ‘‘significant regulatory action’’ under Executive Order 12866; (2) is not a ‘‘significant rule’’ under DOT Regulatory Policies and Procedures (44 FR 11034; February 26, 1979); and (3) does not warrant preparation of a regulatory evaluation as the anticipated impact is so minimal. Since this is a routine matter that will only affect air traffic procedures and air navigation, it is certified that this rule, when promulgated, would not have a significant economic impact on a substantial number of small entities under the criteria of the Regulatory Flexibility Act. (Lat. 48°01′44″ N., long. 098°19′33″ W.) That airspace extending upward from 700 feet above the surface within a 6-mile radius of Lakota Municipal Airport. Environmental Review This proposal will be subject to an environmental analysis in accordance with FAA Order 1050.1F, ‘‘Environmental Impacts: Policies and Procedures’’ prior to any FAA final regulatory action. AGENCY: List of Subjects in 14 CFR Part 71 Airspace, Incorporation by reference, Navigation (air). The Proposed Amendment In consideration of the foregoing, the Federal Aviation Administration proposes to amend 14 CFR part 71 as follows: PART 71—DESIGNATION OF CLASS A, B, C, D, AND E AIRSPACE AREAS; AIR TRAFFIC SERVICE ROUTES; AND REPORTING POINTS 1. The authority citation for 14 CFR part 71 continues to read as follows: ■ Authority: 49 U.S.C. 106(f), 106(g); 40103, 40113, 40120; E.O. 10854, 24 FR 9565, 3 CFR, 1959–1963 Comp., p. 389. § 71.1 [Amended] 2. The incorporation by reference in 14 CFR 71.1 of FAA Order 7400.9Z, Airspace Designations and Reporting Points, dated August 6, 2015, and effective September 15, 2015, is amended as follows: ■ Section 6005 Class E Airspace Areas Extending Upward From 700 Feet or More Above the Surface of the Earth. * * * * * AGL ND E5 LAKOTA, ND [New] Lakota Municipal Airport, ND PO 00000 Frm 00007 Fmt 4702 Sfmt 4702 Issued in Fort Worth, TX, on May 26, 2016. Walter Tweedy, Acting Manager, Operations Support Group, ATO Central Service Center. [FR Doc. 2016–13304 Filed 6–7–16; 8:45 am] BILLING CODE 4910–13–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG–126452–15] RIN 1545–BN06 Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs] Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking and notice of proposed rulemaking by cross-reference to temporary regulations. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. The text of those regulations also serves as part of the text of these proposed regulations. These proposed regulations would impose corporate level tax on certain transactions in which property of a C corporation becomes the property of a REIT. The proposed regulations also make an amendment not addressed in the temporary regulations. The proposed regulations affect RICs, REITs, C corporations the property of which becomes the property of a RIC or a REIT, and their shareholders. DATES: Comments and requests for a public hearing must be received by August 8, 2016. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG–126452–15), Room 5203, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be handdelivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–126452–15), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, DC 20224 or sent electronically via the Federal eRulemaking Portal at http:// SUMMARY: E:\FR\FM\08JNP1.SGM 08JNP1 Federal Register / Vol. 81, No. 110 / Wednesday, June 8, 2016 / Proposed Rules www.regulations.gov/ (IRS REG– 126452–15). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Austin M. Diamond-Jones, (202) 317– 5085; concerning the submission of comments or to request a public hearing, Regina Johnson, (202) 317– 6901 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background and Explanation of Provisions Temporary regulations in the Rules and Regulations section of this issue of the Federal Register amend the Income Tax Regulations (26 CFR part 1) relating to section 337(d). The temporary regulations impose corporate level tax on certain transactions in which property of a C corporation becomes the property of a REIT. The text of those regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the amendments. The proposed regulations also include a modification to the definition of converted property that is not addressed in the temporary regulations. This modification treats as converted property any property the basis of which is determined, directly or indirectly, in whole or in part, by reference to the basis of property owned by a C corporation that becomes the property of a RIC or a REIT. The Treasury Department and the IRS believe that such property presents similar concerns with regard to the purposes of General Utilities repeal as other property of a C corporation that becomes the property of a RIC or REIT. ehiers on DSK5VPTVN1PROD with PROPOSALS Special Analyses Certain IRS regulations, including this one, are exempt from the requirements of Executive Order 12866, as supplemented and reaffirmed by Executive Order 13653. Therefore, a regulatory impact assessment is not required. Pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby certified that these proposed regulations would not have a significant economic impact on a substantial number of small entities. This certification is based on the fact that these proposed regulations would primarily affect large corporations with a substantial number of shareholders. Therefore, a regulatory flexibility analysis is not required. Pursuant to section 7805(f) of the Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business. VerDate Sep<11>2014 14:36 Jun 07, 2016 Jkt 238001 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. The Treasury Department and the IRS request comments on all aspects of the proposed regulations. In particular, comments are requested regarding the scope of the terms predecessors and successors. In addition, although related section 355 distributions occurring before or after conversion transactions involving RICs do not present the same degree of concern regarding the purposes of General Utilities repeal, comments are requested as to whether the proposed regulations regarding related section 355 distributions should, like the rules of § 1.337(d)–7 generally, apply to both conversion transactions involving RICs and conversion transactions involving REITs. 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 written comments. If a public hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the Federal Register. Drafting Information The principal author of these regulations is Austin M. Diamond-Jones of the Office of Associate Chief Counsel (Corporate). 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 revising the entry for § 1.337(d)–7 to read in part as follows: ■ Authority: 26 U.S.C. 7805 . . . * * * * * Section 1.337(d)–7 also issued under 26 U.S.C. 337(d) and 355(h). * * * * * Par. 2. Section 1.337(d)–7 is amended by: ■ 1. Revising paragraph (a)(1) and adding paragraphs (a)(2)(vi) and (vii). ■ PO 00000 Frm 00008 Fmt 4702 Sfmt 4702 36817 2. Revising paragraph (b)(2)(iii). 3. Adding paragraph (b)(4). 4. Revising paragraph (c)(1). 5. Adding paragraph (c)(6). 6. Adding paragraph (f). 7. Revising paragraphs (g)(2)(ii) and (iii). ■ 8. Adding paragraph (g)(2)(iv). The additions and revisions read as follows: ■ ■ ■ ■ ■ ■ § 1.337(d)–7 Tax on property owned by a C corporation that becomes property of a RIC or REIT. (a) General rule. (1) [The text of the proposed amendment to § 1.337(d)– 7(a)(1) is the same as the text of § 1.337(d)–7T(a)(1) published elsewhere in this issue of the Federal Register]. (2) * * * (vi) [The text of the proposed amendment to § 1.337(d)–7(a)(2)(vi) is the same as the text of § 1.337(d)– 7T(a)(2)(vi) published elsewhere in this issue of the Federal Register]. (vii) Converted property. The term converted property means property owned by a C corporation that becomes the property of a RIC or a REIT and any other property the basis of which is determined, directly or indirectly, in whole or in part, by reference to the basis of the property owned by a C corporation that becomes the property of a RIC or a REIT. (b) * * * (2) * * * (iii) [The text of the proposed amendment to § 1.337(d)–7(b)(2)(iii) is the same as the text of § 1.337(d)– 7T(b)(2)(iii) published elsewhere in this issue of the Federal Register]. * * * * * (4) [The text of the proposed amendment to § 1.337(d)–7(b)(4) is the same as the text of § 1.337(d)–7T(b)(4) published elsewhere in this issue of the Federal Register]. * * * * * (c) Election of deemed sale treatment. (1) [The text of the proposed amendment to § 1.337(d)–7(c)(1) is the same as the text of § 1.337(d)–7T(c)(1) published elsewhere in this issue of the Federal Register]. * * * * * (6) [The text of the proposed amendment to § 1.337(d)–7(c)(6) is the same as the text of § 1.337(d)–7T(c)(6) published elsewhere in this issue of the Federal Register]. * * * * * (f) [The text of the proposed amendment to § 1.337(d)–7(f) is the same as the text of § 1.337(d)–7T(f) published elsewhere in this issue of the Federal Register]. (g) * * * E:\FR\FM\08JNP1.SGM 08JNP1 36818 Federal Register / Vol. 81, No. 110 / Wednesday, June 8, 2016 / Proposed Rules (2) * * * (ii) Conversion transactions occurring on or after June 7, 2016. Paragraphs (a)(1), (a)(2)(vi), (b)(4), (c)(1), (c)(6), and (f) of this section will apply to conversion transactions occurring on or after June 7, 2016 and to conversion transactions and related section 355 distributions for which the conversion transaction occurs before, and the related section 355 distribution occurs on or after, June 7, 2016. For conversion transactions that occurred on or after January 2, 2002 and before June 7, 2016, see § 1.337(d)–7 as contained in 26 CFR part 1 in effect on April 1, 2016. (iii) [The text of the proposed amendment to § 1.337(d)–7(g)(2)(iii) is the same as the text of § 1.337(d)– 7T(g)(2)(iii) published elsewhere in this issue of the Federal Register]. (iv) Converted property. Paragraph (a)(2)(vii) of this section applies to conversion transactions that occur on or after the date these regulations are published in the Federal Register as final regulations. John Dalrymple, Deputy Commissioner for Services and Enforcement. [FR Doc. 2016–13425 Filed 6–7–16; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF LABOR Mine Safety and Health Administration 30 CFR Parts 56 and 57 [Docket No. MSHA–2014–0030] RIN 1219–AB87 Examinations of Working Places in Metal and Nonmetal Mines Mine Safety and Health Administration, Labor. ACTION: Proposed rule; notice of public hearings. AGENCY: The Mine Safety and Health Administration (MSHA) is proposing to amend the Agency’s standards for the examination of working places in metal and nonmetal (MNM) mines. The purpose of this proposed rule is to ensure that mine operators identify and correct conditions that may adversely affect miners’ safety or health. MSHA is proposing to require that an examination of the working place be conducted before miners begin work in ehiers on DSK5VPTVN1PROD with PROPOSALS SUMMARY: an area and that the operator notifies miners in the working place of any conditions found that may adversely affect their safety or health. MSHA is also proposing that the competent person conducting the examination sign and date the examination record before the end of each shift, that the record includes information regarding adverse conditions found and corrective actions taken, and that operators make such records available to miners and their representatives. The proposal would enhance the quality of working place examinations in MNM mines and help assure that violations of mandatory health or safety standards are identified and corrected, thereby improving protections for miners. DATES: Comments must be received or postmarked by midnight Eastern Time on September 6, 2016. Hearing Dates: July 19, 2016, July 21, 2016, July 26, 2016, and August 4, 2016. The locations are listed in the Public Hearings section in the SUPPLEMENTARY INFORMATION section of this document. Post-hearing comments must be received by midnight Eastern Standard Time on September 6, 2016. ADDRESSES: Submit comments and informational materials, identified by RIN 1219–AB87 or Docket No. MSHA– 2014–0030, by one of the following methods: • Federal E-Rulemaking Portal: http://www.regulations.gov. Follow the on-line instructions for submitting comments. • E-Mail: zzMSHA-comments@ dol.gov. • Mail: MSHA, Office of Standards, Regulations, and Variances, 201 12th Street South, Suite 4E401, Arlington, Virginia 22202–5452. • Hand Delivery or Courier: 201 12th Street South, Suite 4E401, Arlington, Virginia, between 9:00 a.m. and 5:00 p.m. Monday through Friday, except Federal holidays. Sign in at the receptionist’s desk on the 4th floor East, Suite 4E401. • Fax: 202–693–9441. Information Collection Requirements: Comments concerning the information collection requirements of this proposed rule must be clearly identified with RIN 1219–AB87 or Docket No. MSHA–2014– 0030, and sent to both MSHA and the Office of Management and Budget (OMB). Comments to MSHA may be sent by one of the methods in the ADDRESSES section above. Comments to OMB may be sent by mail addressed to the Office of Information and Regulatory Affairs, Office of Management and Budget, New Executive Office Building, 725 17th Street NW., Washington, DC 20503, Attn: Desk Officer for MSHA. Instructions: All submissions must include RIN 1219–AB87 or Docket No. MSHA–2014–0030. Do not include personal information that you do not want publicly disclosed; MSHA will post all comments without change, including any personal information provided. Docket: For access to the docket to read comments received, go to http:// www.regulations.gov or http:// www.msha.gov/currentcomments.asp. To read background documents, go to http://www.regulations.gov. Review the docket in person at MSHA, Office of Standards, Regulations, and Variances, 201 12th Street South, Arlington, Virginia, between 9:00 a.m. and 5:00 p.m. EST Monday through Friday, except Federal holidays. Sign in at the receptionist’s desk on the 4th floor East, Suite 4E401. E-Mail Notification: To subscribe to receive an email notification when MSHA publishes rules in the Federal Register, go to http://www.msha.gov. SUPPLEMENTARY INFORMATION: Table of Contents I. Introduction A. Public Hearings B. Statutory and Regulatory History II. Background Information III. Section-by-Section Analysis IV. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: Improving Regulation and Regulatory Review V. Feasibility VI. Regulatory Flexibility Analysis and Small Business Regulatory Enforcement Fairness Act VII. Paperwork Reduction Act of 1995 VIII. Other Regulatory Considerations IX. References I. Introduction A. Public Hearings MSHA will hold four public hearings on the proposed rule to provide the public with an opportunity to present oral statements, written comments, and other information on this rulemaking. The public hearings will begin at 9 a.m. and end after the last presenter speaks, and in any event not later than 5 p.m., on the following dates at the locations indicated: Date Location July 19, 2016 .......................................... Homewood Suites by Hilton, Salt Lake City–Downtown, 423 West 300 South, Salt Lake City, UT 84101. VerDate Sep<11>2014 14:36 Jun 07, 2016 Jkt 238001 PO 00000 Frm 00009 Fmt 4702 Sfmt 4702 E:\FR\FM\08JNP1.SGM Contact number 08JNP1 (801) 363–6700

Agencies

[Federal Register Volume 81, Number 110 (Wednesday, June 8, 2016)]
[Proposed Rules]
[Pages 36816-36818]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-13425]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-126452-15]
RIN 1545-BN06


Certain Transfers of Property to Regulated Investment Companies 
[RICs] and Real Estate Investment Trusts [REITs]

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of proposed rulemaking 
by cross-reference to temporary regulations.

-----------------------------------------------------------------------

SUMMARY: In the Rules and Regulations section of this issue of the 
Federal Register, the IRS is issuing temporary regulations effecting 
the repeal of the General Utilities doctrine by the Tax Reform Act of 
1986. The text of those regulations also serves as part of the text of 
these proposed regulations. These proposed regulations would impose 
corporate level tax on certain transactions in which property of a C 
corporation becomes the property of a REIT. The proposed regulations 
also make an amendment not addressed in the temporary regulations. The 
proposed regulations affect RICs, REITs, C corporations the property of 
which becomes the property of a RIC or a REIT, and their shareholders.

DATES:  Comments and requests for a public hearing must be received by 
August 8, 2016.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-126452-15), Room 
5203, Internal Revenue Service, PO Box 7604, Ben Franklin Station, 
Washington, DC 20044. 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-
126452-15), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW., Washington, DC 20224 or sent electronically via the Federal 
eRulemaking Portal at http://

[[Page 36817]]

www.regulations.gov/ (IRS REG-126452-15).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Austin M. Diamond-Jones, (202) 317-5085; concerning the submission of 
comments or to request a public hearing, Regina Johnson, (202) 317-6901 
(not toll-free numbers).

SUPPLEMENTARY INFORMATION: 

Background and Explanation of Provisions

    Temporary regulations in the Rules and Regulations section of this 
issue of the Federal Register amend the Income Tax Regulations (26 CFR 
part 1) relating to section 337(d). The temporary regulations impose 
corporate level tax on certain transactions in which property of a C 
corporation becomes the property of a REIT. The text of those 
regulations also serves as the text of these proposed regulations. The 
preamble to the temporary regulations explains the amendments.
    The proposed regulations also include a modification to the 
definition of converted property that is not addressed in the temporary 
regulations. This modification treats as converted property any 
property the basis of which is determined, directly or indirectly, in 
whole or in part, by reference to the basis of property owned by a C 
corporation that becomes the property of a RIC or a REIT. The Treasury 
Department and the IRS believe that such property presents similar 
concerns with regard to the purposes of General Utilities repeal as 
other property of a C corporation that becomes the property of a RIC or 
REIT.

Special Analyses

    Certain IRS regulations, including this one, are exempt from the 
requirements of Executive Order 12866, as supplemented and reaffirmed 
by Executive Order 13653. Therefore, a regulatory impact assessment is 
not required. Pursuant to the Regulatory Flexibility Act (5 U.S.C. 
chapter 6), it is hereby certified that these proposed regulations 
would not have a significant economic impact on a substantial number of 
small entities. This certification is based on the fact that these 
proposed regulations would primarily affect large corporations with a 
substantial number of shareholders. Therefore, a regulatory flexibility 
analysis is not required. Pursuant to section 7805(f) of the Code, this 
regulation has been submitted to the Chief Counsel for 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. 
The Treasury Department and the IRS request comments on all aspects of 
the proposed regulations. In particular, comments are requested 
regarding the scope of the terms predecessors and successors. In 
addition, although related section 355 distributions occurring before 
or after conversion transactions involving RICs do not present the same 
degree of concern regarding the purposes of General Utilities repeal, 
comments are requested as to whether the proposed regulations regarding 
related section 355 distributions should, like the rules of Sec.  
1.337(d)-7 generally, apply to both conversion transactions involving 
RICs and conversion transactions involving REITs. 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 
written comments. If a public hearing is scheduled, notice of the date, 
time, and place of the public hearing will be published in the Federal 
Register.

Drafting Information

    The principal author of these regulations is Austin M. Diamond-
Jones of the Office of Associate Chief Counsel (Corporate). 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 revising 
the entry for Sec.  1.337(d)-7 to read in part as follows:

    Authority: 26 U.S.C. 7805 . . .
* * * * *
    Section 1.337(d)-7 also issued under 26 U.S.C. 337(d) and 
355(h).

* * * * *
0
Par. 2. Section 1.337(d)-7 is amended by:
0
1. Revising paragraph (a)(1) and adding paragraphs (a)(2)(vi) and 
(vii).
0
2. Revising paragraph (b)(2)(iii).
0
3. Adding paragraph (b)(4).
0
4. Revising paragraph (c)(1).
0
5. Adding paragraph (c)(6).
0
6. Adding paragraph (f).
0
7. Revising paragraphs (g)(2)(ii) and (iii).
0
8. Adding paragraph (g)(2)(iv).
    The additions and revisions read as follows:


Sec.  1.337(d)-7  Tax on property owned by a C corporation that becomes 
property of a RIC or REIT.

    (a) General rule. (1) [The text of the proposed amendment to Sec.  
1.337(d)-7(a)(1) is the same as the text of Sec.  1.337(d)-7T(a)(1) 
published elsewhere in this issue of the Federal Register].
    (2) * * *
    (vi) [The text of the proposed amendment to Sec.  1.337(d)-
7(a)(2)(vi) is the same as the text of Sec.  1.337(d)-7T(a)(2)(vi) 
published elsewhere in this issue of the Federal Register].
    (vii) Converted property. The term converted property means 
property owned by a C corporation that becomes the property of a RIC or 
a REIT and any other property the basis of which is determined, 
directly or indirectly, in whole or in part, by reference to the basis 
of the property owned by a C corporation that becomes the property of a 
RIC or a REIT.
    (b) * * *
    (2) * * *
    (iii) [The text of the proposed amendment to Sec.  1.337(d)-
7(b)(2)(iii) is the same as the text of Sec.  1.337(d)-7T(b)(2)(iii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (4) [The text of the proposed amendment to Sec.  1.337(d)-7(b)(4) 
is the same as the text of Sec.  1.337(d)-7T(b)(4) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (c) Election of deemed sale treatment. (1) [The text of the 
proposed amendment to Sec.  1.337(d)-7(c)(1) is the same as the text of 
Sec.  1.337(d)-7T(c)(1) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (6) [The text of the proposed amendment to Sec.  1.337(d)-7(c)(6) 
is the same as the text of Sec.  1.337(d)-7T(c)(6) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (f) [The text of the proposed amendment to Sec.  1.337(d)-7(f) is 
the same as the text of Sec.  1.337(d)-7T(f) published elsewhere in 
this issue of the Federal Register].
    (g) * * *

[[Page 36818]]

    (2) * * *
    (ii) Conversion transactions occurring on or after June 7, 2016. 
Paragraphs (a)(1), (a)(2)(vi), (b)(4), (c)(1), (c)(6), and (f) of this 
section will apply to conversion transactions occurring on or after 
June 7, 2016 and to conversion transactions and related section 355 
distributions for which the conversion transaction occurs before, and 
the related section 355 distribution occurs on or after, June 7, 2016. 
For conversion transactions that occurred on or after January 2, 2002 
and before June 7, 2016, see Sec.  1.337(d)-7 as contained in 26 CFR 
part 1 in effect on April 1, 2016.
    (iii) [The text of the proposed amendment to Sec.  1.337(d)-
7(g)(2)(iii) is the same as the text of Sec.  1.337(d)-7T(g)(2)(iii) 
published elsewhere in this issue of the Federal Register].
    (iv) Converted property. Paragraph (a)(2)(vii) of this section 
applies to conversion transactions that occur on or after the date 
these regulations are published in the Federal Register as final 
regulations.

John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2016-13425 Filed 6-7-16; 8:45 am]
 BILLING CODE 4830-01-P