Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs], 36816-36818 [2016-13425]
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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 https://www.regulations.gov.
Recently published rulemaking
documents can also be accessed through
the FAA’s Web page at https://
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.
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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
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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 https://
SUMMARY:
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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.
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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).
■
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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) * * *
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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:
https://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 https://
www.regulations.gov or https://
www.msha.gov/currentcomments.asp.
To read background documents, go to
https://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 https://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.
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Contact number
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(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]
=======================================================================
-----------------------------------------------------------------------
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 https://
[[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
