[Federal Register Volume 64, Number 62 (Thursday, April 1, 1999)]
[Rules and Regulations]
[Page 15687]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-7792]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1, 7, and 602
[TD 8770]
RIN 1545-AP81 and 1545-AI32
Certain Transfers of Stock or Securities by U.S. Persons to
Foreign Corporations and Related Reporting Requirements; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to final regulations.
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SUMMARY: This document contains corrections to Treasury Decision 8770,
which was published in the Federal Register on Friday, June 19, 1998
(63 FR 33550) relating to certain transfers of stock or securities by
U.S. persons to foreign corporations pursuant to the corporate
organization and reorganization provisions of the Internal Revenue
Code, and the reporting requirements related to such transfers.
DATES: These corrections are effective July 20, 1998.
FOR FURTHER INFORMATION CONTACT: Philip L. Tretiak, (202) 622-3860 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the subject of these corrections are
under sections 367 and 6038B of the Internal Revenue Code.
Need for Correction
As published, TD 8770 contains errors which may prove to be
misleading and are in need of clarification.
Correction of Publication
Accordingly, the publication of the final regulations (TD 8770),
which was the subject of FR Doc. 98-15454, is corrected as follows:
1. On page 33555, column 2, in the preamble under the paragraph
heading ``Effective Dates'', line 19, the language ``a United States
shareholder but does'' is corrected to read ``a United States
shareholder but does not''.
Sec. 1.367(a)-3 [Corrected]
2. On page 33556, column 1, Sec. 1.367(a)-3(a), lines 22 through
24, the language ``a U.S. person exchanges stock of one foreign
corporation for stock of another foreign corporation in a
reorganization'' is corrected to read ``a U.S. person exchanges stock
of a foreign corporation in a reorganization''.
3. On page 33556, column 1, Sec. 1.367(a)-3(a), line 27, the
language ``domestic corporation for stock of a'' is corrected to read
``domestic or foreign corporation for stock of a''.
4. On page 33559, column 1, Sec. 1.367(a)-3(d)(3), paragraph (ii)
of Example 6, line 10, the language ``Sec. 1.367(a)-8(g)(3)(i) (which
includes the'' is corrected to read Sec. 1.367(a)-8(g)(3) (which
includes the''.
Sec. 1.367(b)-4 [Corrected]
5. On page 33568, column 1, Sec. 1.367(b)-4(b)(5)(i), line 4, the
language ``transaction described in paragraph (b)(1)'' is corrected to
read ``transaction described in paragraph (a)''.
6. On page 33568, column 2, Sec. 1.367(b)-4(b)(5)(ii), paragraph
(ii) of the Example, line 2, the language ``an exchange described in
paragraph (b) of'' is corrected to read ``an exchange described in
paragraph (a) of''.
Sec. 1.6038B-1 [Corrected]
7. On page 33569, column 1, Sec. 1.6038B-1(b)(2)(i) introductory
text, line 4, the language ``in section 6038(a)(1)(A) will be'' is
corrected to read ``in section 6038B(a)(1)(A) will be''.
Cynthia E. Grigsby,
Chief, Regulations Unit, Assistant Chief Counsel (Corporate).
[FR Doc. 99-7792 Filed 3-31-99; 8:45 am]
BILLING CODE 4830-01-U `
