Department of Treasury February 21, 2006 – Federal Register Recent Federal Regulation Documents

Open Meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel
Document Number: E6-2369
Type: Notice
Date: 2006-02-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel will be conducted (via teleconference). The Taxpayer Advocacy Panel (TAP) is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign Corporations
Document Number: 06-1465
Type: Rule
Date: 2006-02-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that address the interaction of section 304 and section 367. These regulations provide that section 367(a) and (b) do not apply to a deemed section 351 exchange resulting from a section 304(a)(1) transaction. These regulations may apply to taxpayers transferring stock to related foreign corporations.
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