Legal Status
Legal Status
Proposed Rule
Requirements Relating to Certain Exchanges Involving a Foreign Corporation
A Proposed Rule by the Internal Revenue Service on
Document Details
Information about this document as published in the Federal Register.
- Printed version:
- Publication Date:
- 01/12/2001
- Agencies:
- Internal Revenue Service
- Document Type:
- Proposed Rule
- Document Citation:
- 66 FR 2856
- Page:
- 2856 (1 page)
- CFR:
- 26 CFR 7
- Agency/Docket Number:
- LR-230-76
- Document Number:
- 01-490
Document Details
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Published Document
This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Withdrawal of notice of proposed regulations.
SUMMARY:
This document withdraws proposed regulations under section 367(c). The proposed regulations correspond to temporary regulations that are also being removed in this issue of the Federal Register. The temporary regulations are being removed because they are no longer necessary and, as a result, may be misleading.
Start Further InfoFOR FURTHER INFORMATION CONTACT:
Mark D. Harris at (202) 622-3860 (not a toll-free number).
End Further Info End Preamble Start Supplemental InformationSUPPLEMENTARY 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since enactment of the Act and, moreover, in light of the fact that §§ 1.367(b)-1 through 1.367(b)-6 have substantially superceded §§ 7.367(b)-1 through 7.367(b)-12, §§ 7.367(c)-1 and 7.367(c)-2 are no longer necessary and may be misleading.
Accordingly, the IRS and Treasury are removing temporary regulations §§ 7.367(c)-1 and 7.367(c)-2 in this issue of the Federal Register. Correspondingly, this document removes proposed regulations §§ 7.367(c)-1 and 7.367(c)-2.
Start List of SubjectsList of Subjects in 26 CFR Part 7
- Income taxes
- Reporting and recordkeeping requirements
Withdrawal of Proposed Amendments to the Regulations
Accordingly, under the authority of 26 U.S.C. 7805, proposed regulations under 26 CFR part 7 relating to §§ 7.367(c)-1 and 7.367(c)-2, published December 30, 1977 (42 FR 65204), are withdrawn.
Start SignatureRobert E. Wenzel,
Deputy Commissioner of Internal Revenue.
[FR Doc. 01-490 Filed 1-11-01; 8:45 am]
BILLING CODE 4830-01-U