Inversions and Related Transactions; Correction, 40810 [2016-14648]

Download as PDF 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. asabaliauskas on DSK3SPTVN1PROD with RULES 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.

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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