Inversions and Related Transactions; Correction, 40810 [2016-14648]
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40810
Federal Register / Vol. 81, No. 121 / Thursday, June 23, 2016 / Rules and Regulations
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9761]
RIN 1545–BM88
Inversions and Related Transactions;
Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Final and temporary
regulations; correction.
AGENCY:
This document contains
corrections to final and temporary
regulations (TD 9761) that were
published in the Federal Register on
April 8, 2016 (81 FR 20858). The
temporary regulations address
transactions that are structured to avoid
the purposes of sections 7874 and 367
of the Internal Revenue Code and
certain post-inversion tax avoidance
transactions.
SUMMARY:
This correction is effective on
June 23, 2016 and applicable on April
8, 2016.
FOR FURTHER INFORMATION CONTACT: Rose
E. Jenkins at (202) 317–6934 (not a toll
free number).
SUPPLEMENTARY INFORMATION:
DATES:
Background
The final and temporary regulations
(TD 9761) that are the subject of this
correction are under sections 304, 367,
956, 7701(l), and 7874 of the Internal
Revenue Code.
Need for Correction
As published, the final and temporary
regulations (TD 9761) contain errors that
may prove to be misleading and are in
need of clarification.
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Correction of Publication
Accordingly, the final and temporary
regulations (TD 9761), that are the
subject of FR Doc. 2016–07300, are
corrected as follows:
1. On page 20858, in the preamble,
the second column, the ninth line from
the bottom of the column, the language
‘‘section 7874 and § 1.367(a)–3(c) and’’
is corrected to read ‘‘section 7874 and’’.
2. On page 20860, in the preamble,
the third column, under the paragraph
heading ‘‘E. Section 7701’’, the language
‘‘re-characterizing’’ and ‘‘recharacterization’’ is corrected to read
‘‘recharacterizing’’ and
‘‘recharacterization’’ respectively
wherever it appears.
3. On page 20862, in the preamble,
the third column, under the paragraph
VerDate Sep<11>2014
16:58 Jun 22, 2016
Jkt 238001
heading ‘‘a. § 1.7874–4T, In General’’
the fifth and sixth lines, the language
‘‘entity acquisition described in section
7874(a)(2)(B)(i) is excluded from the’’ is
corrected to read ‘‘entity acquisition is
excluded from the’’.
4. On page 20869, in the preamble,
the first column, the twenty-fifth line
from the bottom of the column, the
language ‘‘60% or 80% on the
completion date.’’ is corrected to read
‘‘60 or 80 on the completion date.’’.
5. On page 20871, in the preamble,
the second column, the third and tenth
lines from the top of the first full
paragraph, the language ‘‘domestic’’ is
removed.
6. On page 20873, in the preamble,
the third column, under the paragraph
heading ‘‘II. Rules Addressing Certain
Post-Inversions Tax Avoidance
Transactions’’ the first line, the
language ‘‘As stated in Section 1 of the
2014’’ is corrected to read ‘‘As stated in
section 1 of the 2014’’.
7. On page 20874, in the preamble,
the third column, the twenty-second
line from the top of the column, the
language ‘‘completion date, is treated as
an’’ is corrected to read ‘‘completion
date is treated as an’’.
8. On page 20877, in the preamble,
the first column, under the paragraph
heading ‘‘ii. Exceptions From
Recharacterization’’ the twelfth line of
the first full paragraph, the language
‘‘recognized. See Section 2.C of this
Part’’ is corrected to read ‘‘recognized.
See Section 2.c of this Part’’.
9. On page 20880, in the preamble,
the first column, under the paragraph
heading ‘‘b. Regulations Implementing
the Section 367(b) Asset Dilution Rule’’
the third line from the bottom of the
column, the language ‘‘property to a
foreign transferee’’ is corrected to read
‘‘property to a transferee foreign’’.
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
Final and temporary
regulations; correcting amendment.
ACTION:
This document contains
corrections to final and temporary
regulations (TD 9761) that were
published in the Federal Register on
April 8, 2016 (81 FR 20858). The
temporary regulations address
transactions that are structured to avoid
the purposes of sections 7874 and 367
of the Internal Revenue Code and
certain post-inversion tax avoidance
transactions.
SUMMARY:
This correction is effective on
June 23, 2016 and applicable on April
8, 2016.
FOR FURTHER INFORMATION CONTACT: Rose
E. Jenkins at (202) 317–6934 (not a toll
free number).
SUPPLEMENTARY INFORMATION:
DATES:
Background
The final and temporary regulations
(TD 9761) that are the subject of this
correction are under sections 304, 367,
956, 7701(l), and 7874 of the Internal
Revenue Code.
Need for Correction
As published, the final and temporary
regulations (TD 9761) contain errors that
may prove to be misleading and are in
need of clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
Authority: 26 U.S.C. 7805 * * *
BILLING CODE 4830–01–P
Par. 2. Section 1.304–7T is amended
by revising paragraph (f) to read as
follows:
DEPARTMENT OF THE TREASURY
§ 1.304–7T Certain acquisitions by foreign
acquiring corporations (temporary).
Internal Revenue Service
*
[FR Doc. 2016–14648 Filed 6–22–16; 8:45 am]
*
*
*
*
(f) Expiration date. This section
expires on or before April 4, 2019.
■ Par. 3. Section 1.367(a)–3T is
amended by revising paragraph (k) to
read as follows:
26 CFR Part 1
[TD 9761]
RIN 1545–BM88
Inversions and Related Transactions;
Correction
Internal Revenue Service (IRS),
Treasury.
AGENCY:
PO 00000
Frm 00032
Fmt 4700
Sfmt 4700
■
§ 1.367(a)–3T Treatment of transfers of
stock or securities to foreign corporations
(temporary).
*
E:\FR\FM\23JNR1.SGM
*
*
23JNR1
*
*
]]>Agencies
[Federal Register Volume 81, Number 121 (Thursday, June 23, 2016)]
[Rules and Regulations]
[Page 40810]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-14648]
[[Page 40810]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9761]
RIN 1545-BM88
Inversions and Related Transactions; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final and temporary regulations; correction.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to final and temporary
regulations (TD 9761) that were published in the Federal Register on
April 8, 2016 (81 FR 20858). The temporary regulations address
transactions that are structured to avoid the purposes of sections 7874
and 367 of the Internal Revenue Code and certain post-inversion tax
avoidance transactions.
DATES: This correction is effective on June 23, 2016 and applicable on
April 8, 2016.
FOR FURTHER INFORMATION CONTACT: Rose E. Jenkins at (202) 317-6934 (not
a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9761) that are the subject
of this correction are under sections 304, 367, 956, 7701(l), and 7874
of the Internal Revenue Code.
Need for Correction
As published, the final and temporary regulations (TD 9761) contain
errors that may prove to be misleading and are in need of
clarification.
Correction of Publication
Accordingly, the final and temporary regulations (TD 9761), that
are the subject of FR Doc. 2016-07300, are corrected as follows:
1. On page 20858, in the preamble, the second column, the ninth
line from the bottom of the column, the language ``section 7874 and
Sec. 1.367(a)-3(c) and'' is corrected to read ``section 7874 and''.
2. On page 20860, in the preamble, the third column, under the
paragraph heading ``E. Section 7701'', the language ``re-
characterizing'' and ``re-characterization'' is corrected to read
``recharacterizing'' and ``recharacterization'' respectively wherever
it appears.
3. On page 20862, in the preamble, the third column, under the
paragraph heading ``a. Sec. 1.7874-4T, In General'' the fifth and
sixth lines, the language ``entity acquisition described in section
7874(a)(2)(B)(i) is excluded from the'' is corrected to read ``entity
acquisition is excluded from the''.
4. On page 20869, in the preamble, the first column, the twenty-
fifth line from the bottom of the column, the language ``60% or 80% on
the completion date.'' is corrected to read ``60 or 80 on the
completion date.''.
5. On page 20871, in the preamble, the second column, the third and
tenth lines from the top of the first full paragraph, the language
``domestic'' is removed.
6. On page 20873, in the preamble, the third column, under the
paragraph heading ``II. Rules Addressing Certain Post-Inversions Tax
Avoidance Transactions'' the first line, the language ``As stated in
Section 1 of the 2014'' is corrected to read ``As stated in section 1
of the 2014''.
7. On page 20874, in the preamble, the third column, the twenty-
second line from the top of the column, the language ``completion date,
is treated as an'' is corrected to read ``completion date is treated as
an''.
8. On page 20877, in the preamble, the first column, under the
paragraph heading ``ii. Exceptions From Recharacterization'' the
twelfth line of the first full paragraph, the language ``recognized.
See Section 2.C of this Part'' is corrected to read ``recognized. See
Section 2.c of this Part''.
9. On page 20880, in the preamble, the first column, under the
paragraph heading ``b. Regulations Implementing the Section 367(b)
Asset Dilution Rule'' the third line from the bottom of the column, the
language ``property to a foreign transferee'' is corrected to read
``property to a transferee foreign''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2016-14648 Filed 6-22-16; 8:45 am]
BILLING CODE 4830-01-P
