E7-5603. Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction  

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    AGENCY:

    Internal Revenue Service (IRS), Treasury.

    ACTION:

    Correcting amendment.

    SUMMARY:

    This document contains correction to temporary regulations (TD 9313) that were published in the Federal Register on Thursday, March 1, 2007 (72 FR 9262) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation are issued and distributed in the transaction.

    DATES:

    This amendment is effective March 29, 2007.

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    FOR FURTHER INFORMATION CONTACT:

    Bruce A. Decker at (202) 622-7550 (not a toll-free number).

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    SUPPLEMENTARY INFORMATION:

    Background

    The temporary regulations that are the subjects of this correction are under section 368 of the Internal Revenue Code.

    Need for Correction

    As published, temporary regulations (TD 9313) contain an error that may prove to be misleading and is in need of clarification.

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    List of Subjects in 26 CFR Part 1

    • Income taxes
    • Reporting and recordkeeping requirements
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    Correction of Publication

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    Accordingly, 26 CFR part 1 is corrected by making the following amendments:

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    PART 1—INCOME TAXES

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    Paragraph 1. The authority citation for part 1 continues to read, in part, as follows:

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    Authority: 26 U.S.C. 7805 * * *

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    Par. 2. Section 1.368-2T is amended by revising paragraph (l)(2)(iv) to read as follows:

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    Definition of terms (temporary).
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    (l) * * *

    (2) * * *

    (iv) Exception. This paragraph (l)(2) of this section does not apply to a transaction otherwise described in § 1.358-6(b)(2) or section 368(a)(1)(G) by reason of section 368(a)(2)(D).

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    LaNita Van Dyke,

    Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

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    [FR Doc. E7-5603 Filed 3-28-07; 8:45 am]

    BILLING CODE 4830-01-P

Document Information

Effective Date:
3/29/2007
Published:
03/29/2007
Department:
Internal Revenue Service
Entry Type:
Rule
Action:
Correcting amendment.
Document Number:
E7-5603
Dates:
This amendment is effective March 29, 2007.
Pages:
14678-14678 (1 pages)
Docket Numbers:
TD 9313
RINs:
1545-BG29
Topics:
Income taxes, Reporting and recordkeeping requirements
PDF File:
E7-5603.Pdf
CFR: (1)
26 CFR 1.368-2T