Internal Revenue Service (IRS), Treasury.
Removal of temporary regulations.
This document removes temporary regulations under section 367(c) that are no longer necessary and, as a result, may be misleading.
Effective Date: January 12, 2001.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Mark D. Harris at (202) 622-3860 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
On December 30, 1977, the IRS and Treasury published in the Federal Register proposed regulations (42 FR 65204) and temporary regulations (42 FR 65152) under section 367(c) of the Internal Revenue Code. The principal purpose of these regulations, §§ 7.367(c)-1 and 7.367(c)-2, was to distinguish between the treatment of transfers described in section 367(c) before and after the enactment of the Tax Reform Act of 1976 (the Act) (90 Stat. 1634). Before enactment of the Act, transfers described in section 367(c) were subject to a ruling requirement. After enactment of the Act, transfers described in section 367(c) were within the scope of §§ 7.367(b)-1 through 7.367(b)-12. In light of the substantial time that has passed since enactment of the Act and, moreover, in light of the fact that §§ 1.367(b)-1 through 1.367(b)-6 have substantially superceded §§ 7.367(b)-1 through 7.367(b)-12, §§ 7.367(c)-1 and 7.367(c)-2 are no longer necessary and may be misleading.Start Amendment Part
Accordingly, this document removes §§ 7.367(c)-1 and 7.367(c)-2.End Amendment Part Start List of Subjects
List of Subjects in 26 CFR Part 7End List of Subjects
Removal of Temporary RegulationsStart Amendment Part
Accordingly, under the authority ofEnd Amendment Part Start Part
PART 7—TEMPORARY INCOME TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1976End Part Start Amendment Part
End Amendment Part
End Amendment Part Start Signature
Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.Approved: December 28, 2000.
Assistant Secretary of the Treasury.
[FR Doc. 01-489 Filed 1-11-01; 8:45 am]
BILLING CODE 4830-01-U