Home » Rulemaking » Treatment of Property Used to Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations

Treatment of Property Used to Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations

Document ID: IRS-2008-0040-0004
Document Type: Rule
Agency: Internal Revenue Service
Topics: Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number: 2011-12279
CFR Citation: 26 CFR Part 1
View Document:

Details Information

Document Subtype:	Final Rule
Received Date:	May 19 2011, at 12:00 AM Eastern Daylight Time
Start-End Page:	28890 - 28895
Comment Start Date:	May 19 2011, at 12:00 AM Eastern Standard Time

Comments

Total: 0

No comments posted.

Related Documents

Total: 304

Information Reporting for Affordable Insurance Exchanges

Noncompensatory Partnership Options: Correction

Regulations Enabling Elections for Certain Transactions under Section 336(e)

Computation of, and Rules Relating to, Medical Loss Ratio

Health Insurance Premium Tax Credit: Minimum Value of Eligible Employer-Sponsored Plans and Other Rules

Outbound Property Transfers by Domestic Corporations: Certain Stock Distributions; Correction

Reporting for Premium

500,000 Dollar Deduction Limitation for Remuneration Provided by Certain Health Insurance Providers

Noncompensatory Partnership Options

Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage

Section 482: Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; CFR Correction

Unified Rule for Loss on Subsidiary Stock; CFR Correction

Treatment of Overall Foreign and Domestic Losses; CFR Correction

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Stewardship Expense; CFR Correction

Unified Rule for Loss on Subsidiary Stock; CFR Correction

Noncompensatory Partnership Options; Correction

Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage; Correction

Indirect Stock Transfers and Coordination Rule Exceptions: Transfers of Stock or Securities in Outbound Asset Reorganizations

Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income

Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated; Correction

Noncompensatory Partnership Options

Treatment of Grantor of Option on Partnership Interest

Health Insurance Premium Tax Credit

Net Investment Income Tax; Correction

Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage

Failure To File Gain Recognition Agreements and Other Required Filings

Rules Relating to Additional Medicare Tax; Correction

Partners Distributive Share; Correction

Disclosure or Use of Information by Preparers of Returns; Correction

Treasury Inflation-Protected Securities Issued at a Premium; Bond Premium Carryforward

Bond Premium Carryforward

Treasury Inflation-Protected Securities Issued at a Premium; Bond Premium Carryforward

Bond Premium Carryforward

Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated

Partners Distributive Share

Use of Controlled Corporations to Avoid the Application of Section 304

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Allocation of Costs Under the Simplified Methods; Hearing

Deduction for Qualified Film and Television Production Costs

Net Investment Income Tax

Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor in Bankruptcy

Utility Allowances Submetering; Hearing Cancellation

Regulations Regardingthe Application of Section 172(h) Including Consolidated Groups; Correction

Additional Requirements for Charitable Hospitals; Hearing

Basis of Indebtedness of S Corporations to Their Shareholders; Hearing Cancellation

Additional Requirements for Charitable Hospitals: Public Hearings

New Markets Tax Credit Non-Real Estate Investments

Integrated Hedging Transactions of Qualifying Debt

Application of Section 172(h) Including Consolidated Groups

Integrated Hedging Transactions of Qualifying Debt

Allocation of Costs under the Simplified Methods

Dividend Equivalents from Sources within the United States; Amendment Correction

Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor in Bankruptcy: Hearing Cancellation

Deductions for Entertainment Use of Business Aircraft; Correction

Additional Requirements for Charitable Hospitals; Correction

Utility Allowances Submetering

Deductions for Entertainment Use of Business Aircraft

Reimbursed Entertainment Expenses

Health Insurance Premium Tax Credit; Correction

Basis of Indebtedness of S Corporations to Their Shareholders; Correction

Substantial Business Activities: Correction

Additional Requirements for Charitable Hospitals

Overall Foreign Loss Recapture on Property Dispositions

Treatment of Overall Foreign and Domestic Losses

Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor In Bankruptcy

Financial Asset Securitization Investment Trusts

Property Transferred in Connection with Performance of Services under Section 83

Basis of Indebtedness of S Corporations to their Shareholders

Substantial Business Activities

Surrogate Foreign Corporations

Substantial Business Activities

Property Transferred in Connection with Performance of Services under Section83

Regulations Revising Rules Regarding Agency for Consolidated Group

Modifications to Definition of United States Property

Allocation of Mortgage Insurance Premiums

Local Lodging Expenses

Treatment of Gain Recognized with Respect to Stock in Certain Foreign Corporations Upon Distributions

Guidance under Sections 642 and 643 (Income Ordering Rules)

Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts

Deferral of Loss on Transactions between Members of a Controlled Group

Allocation of Earnings and Profits in Tax-Free Transfers from One Corporation to Another

Conduit Financing Arrangements; Correction

Allocation and Apportionment of Interest Expense; Hearing Cancellation

Apportionment of Tax Items Among the Members of a Controlled Group of Corporations; CFR Correction

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Correction

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Treasury Inflation-Protected Securities Issued at a Premium; Hearing Cancellation

Passive Activity Losses and Credits Limited: Hearing

Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension Plans; Correction

Dividend Equivalents from Sources Within the U.S.; Correction

Determination of Governmental Plan Status; Correction

Indian Tribal Government Plans; Correction

Determination of Governmental Plan Status; Correction

Indian Tribal Government Plans; Correction

Reporting of Specified Foreign Financial Assets; Correction

Source of Income from Qualified Fails Charges

Reporting of Specified Foreign Financial Assets; Correction

Allocation and Apportionment of Interest Expense; Correction

Reporting of Specified Foreign Financial Assets; Correction

Furnishing Identifying Number of Tax Return Preparer

Foreign Tax Credit Splitting Events

Section 482: Methods to Determine Taxable Income in Connection with Cost Sharing Arrangement; Correction

Foreign Tax Credit Splitting Events

Section 482: Methods to Determine Taxable Income in Connection with Cost Sharing Arrangement; Correction

Definition of a Taxpayer

Application for Recognition as a 501(c)(29) Organization

Dividend Equivalents from Sources within the United States

Indian Tribal Government Plans

Longevity Annuity Contracts

Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options under Defined Benefit Pension Plans

Determination of Governmental Plan Status

Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Indian Tribal Government Plans

Dividend Equivalents from Sources within the United States

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Public Hearing

Determination of Governmental Plan Status

Dividend Equivalents from Sources within the United States

Damages Received on Account of Personal Physical Injuries or Physical Sickness

Allocation and Apportionment of Interest Expense

Guidance Regarding Deduction and Capitalization ofExpenditures Related to Tangible Property

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Use of Differential Income Stream as Application of Income Method and as Consideration in Assessing Best Method

Use of Differential Income Stream as Consideration in Assessing Best Method

Tax Return Preparer Penalties under Section 6695

Corporate Reorganizations: Guidance on Measurement of Continuity of Interest

Reporting of Specified Foreign Financial Assets

Guidance Regarding Foreign Base Company Sales Income

Reporting of Specified Foreign Financial Assets

Application of Segregation Rules to Small Shareholders: Correction

Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options: Correction

New Markets Tax Credit Non-Real Estate Investments; Hearing Cancellation

Conduit Financing Arrangements

Determination of Governmental Plan Status; Correction

Indian Tribal Governmental Plans; Correction

Targeted Populations Under Section 45D(e)(2)

Treasury Inflation-Protected Securities Issued at a Premium

Passive Activity Losses and Credits Limited

Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options

Application of the Segregation Rules to Small Shareholders

Corporate Reorganizations; Allocation of Basis in All Cash D Reorganizations

Deduction for Qualified Film and Television Production Costs: Correction

Application of Section 108(e)(8) to Indebtedness Satisfied by a Partnership Interest

Indian Tribal Governmental Plans

Determination of Governmental Plan Status

Tax Accounting Elections on Behalf of Foreign Corporations; Withdrawal

Tax Return Preparer Penalties Under Section 6695; Hearing Cancellation

Modifications of Certain Derivative Contracts; Hearing Cancellation

Partner's Distributive Share

Redetermination of the Consolidated Net Unrealized Built-In Gain and Loss

Guidance Regarding the Treatment of Stock of a Controlled Corporation

Tax Return Preparer Penalties Under Section 6695; Correction

Deduction for Qualified Film and Television Production Costs

Tax Return Preparer Penalties Under Section 6695; Correction

Tax Return Preparer Penalties Under Section 6695

Retail Inventory Method

Implementation of Form 990; Correction

Swap Exclusion for Section 1256 Contracts

Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, etc.; Correction

Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

Section 67 Limitations on Estates or Trusts

Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m); Correction

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correction

Methods of Accounting Used by Corporations that Acquire Assets of Other Corporations: Correction

Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correcting Amendment

Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correction

Modifications of Certain Derivative Contracts: Correction

Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses

Health Insurance Premium Tax Credit

Corporate Reorganizations; Distributions under Sections 368(a)(1)(D) and 354(b)(1)(B): Correction

Methods of Accounting Used by Corporations that Acquire Assets of Other Corporations

Election of Reduced Research Credit

Guidance under Section 956 for Determining Basis of Property Acquired in Certain Nonrecognition Transactions; Correction

Modifications of Certain Derivative Contracts

Determining Amount of Taxes Paid for Purposes of Foreign Tax Credit

New Markets Tax Credit Non-Real Estate Investments:Correction

Encouraging New Markets Tax Credit Non-Real Estate Investments: Correction

Modification of Regulations under Dodd-Frank Wall Street Reform and Consumer Protection Act

Guidance under Section 956 for Determining Basis of Property Acquired in Certain Nonrecognition Transactions

Requirements for Taxpayers Filing Form 5472; Correction

Deduction Limitation for Certain Employee Remuneration in Excess of $1,000,000

Alternative Simplified Credit

Claims for Credit or Refund

Requirements for Taxpayers Filing Form 5472

Encouraging New Markets Tax Credit Non-Real Estate Investments

New Markets Tax Credit Non-Real Estate Investments: Public Hearing

Controlled Groups; Deferral of Losses

Controlled Groups; Deferral of Losses; Correction

Reduction of Foreign Tax Credit Limitation Categories; Correction

Modifications to Treatment of Aircraft and Vessel Leasing Income

Controlled Groups; Deferral of Losses

Guidance under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction

Guidance Concerning the Exclusion of Section 61 Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity

Clarification of Controlled Group Qualification Rules

Reduction of Foreign Tax Credit Limitation Categories under Section 904(d)

Guidance under Section 1502: Amendment of Matching Rule for Certain Gains on Member Stock; Correction

Property Traded on Established Market: Hearing Cancellation

Sales-Based Royalties and Vendor Allowances: Public Hearing

Guidance under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock

Time and Manner for Electing Capital Asset Treatment for Certain Self-Created Musical Works

Hybrid Retirement Plans; Correction

Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction

Nuclear Decommissioning Funds; Correction

Property Traded on Established Market

Modifications of Debt Instruments

Source of Income From Qualified Fails Charges; Correction

Hybrid Retirement Plans; Correction

Hybrid Retirement Plans

Sales-Based Royalties and Vendor Allowances

Farmerand Fisherman Income Averaging

Requirement of a Statement Disclosing Uncertain Tax Positions

Source of Income from Qualified Fails Charges

Revised Regulations Concerning Section 403(b) Tax-Sheltered Annuity Contracts: Correction

Hybrid Retirement Plans

Additional Rules Regarding Hybrid Retirement Plans

Exclusions From Gross Income of Foreign Corporations; Correction

Requirements of a Statement Disclosing Uncertain Tax Positions; Correction

Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations, etc.; Correction

Requirement of a Statement Disclosing Uncertain Tax Positions

Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

Clarification to Section 6411 Regulations

Modifications of Debt Instruments; Hearing Cancellation

Application of Section 108(i) to Partnerships and S Corporations

Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations and Deferred Original Issue Discount Deductions

Extended Carryback of Losses to or from Consolidated Groups: Correction

Build-in Gains and Losses Under Section 382(h); Correction

Extended Carryback of Losses to or from a Consolidated Group

Built-in Gains and Losses under Section 382(h)

Contributed Property

Modifications of Debt Instruments

Qualified Nonpersonal Use Vehicles

Diversification Requirements for Certain Defined Contribution Plans

AJCA Modifications to the Section 6011 Regulations; Correction

Furnishing Identifying Number of Tax Return Preparer; Hearing

Exclusions From Gross Income of Foreign Corporations; CFR Correction

Consolidated Returns; Intercompany Obligations; CFR Correction

Furnishing Identifying Number of Tax Return Preparer

Unified Rule for Loss on Subsidiary Stock; Correction

Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income

Use of Controlled Corporations To Avoid the Application of Section 304; Correction

Basis Reporting by Securities Brokers and Basis Determination for Stock; Correction

Modification to Consolidated Return Regulation: Permitting an Election to Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization

Information Reporting Requirements Under Internal Revenue Code Section 6039; Correction

Employee Stock Purchase Plans Under Internal Revenue Code Section 423; Correction

Corporate Reorganizations; Distributions under sections 368(a)(1)(D) and 354(b)(1)(B)

Modification to Consolidated Return Regulation Permitting an Election: Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization; Correction

Clarification of Controlled Group Qualification Rules

Modification to Consolidated Return Regulation Permitting an Election: Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization

Allocations and Reporting of Mortgage Insurance Premiums; Correction

Suspension or Reduction of Safe Harbor Nonelective Contributions

Special Rules To Reduce Section 1446 Withholding; Correction

Gain Recognition Agreements With Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction

Guidance Regarding Foreign Base Company Sales Income

Guidance Regarding Foreign Base Company Sales Income; Correction

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Application of Section 367 to a Section 351 Exchange, etc.: Correction

Applications: Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1), etc.; Correction

Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction

Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities; Correction

Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Section 482; Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement; Correction

Further Guidance on the Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Notice to Participants of Consequences of Failing to Defer Receipt of Qualified Retirement Plan Distributions: Expansion of Applicable Election Period and Period for Notices; Hearing Cancellation

Section 108(e)(8) Application to Partnerships; Hearing Cancellation

Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1): Treatment of Gain Recognized under Section 301(c)(3) for Purposes of Section 1248

Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1)

Consolidated Returns; Intercompany Obligations; Correction

Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction

Guidance Regarding Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction

Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction

Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities

Section 707 Regarding Disguised Sales, Generally