Skip to Content

Rule

Requirements Relating to Certain Exchanges Involving a Foreign Corporation

Document Details

Information about this document as published in the Federal Register.

Published Document

This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.

Start Preamble

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Removal of temporary regulations.

SUMMARY:

This document removes temporary regulations under section 367(c) that are no longer necessary and, as a result, may be misleading.

DATES:

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

SUPPLEMENTARY INFORMATION:

Background

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since enactment of the Act and, moreover, in light of the fact that §§ 1.367(b)-1 through 1.367(b)-6 have substantially superceded §§ 7.367(b)-1 through 7.367(b)-12, §§ 7.367(c)-1 and 7.367(c)-2 are no longer necessary and may be misleading.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 7

End List of Subjects

Removal of Temporary Regulations

Start Amendment Part

Accordingly, under the authority of

End Amendment Part Start Part

PART 7—TEMPORARY INCOME TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1976

End Part Start Amendment Part

End Amendment Part Start Authority

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

End Authority
Start Printed Page 2822
[Amended]
Start Amendment Part

End Amendment Part Start Signature

Robert E. Wenzel,

Deputy Commissioner of Internal Revenue.

Approved: December 28, 2000.

Jonathan Talisman,

Assistant Secretary of the Treasury.

End Signature End Supplemental Information

[FR Doc. 01-489 Filed 1-11-01; 8:45 am]

BILLING CODE 4830-01-U