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

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.

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AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document contains a correction to final and temporary regulations (TD 9383) that were published in the Federal Register on Friday, March 7, 2008 (73 FR 12265). Concerning the treatment of certain intercompany gain with respect to consolidated group member stock. These amendments provide for the redetermination of an intercompany gain as excluded from gross income in certain member stock transactions. These regulations affect corporations filing consolidated returns.

DATES:

This correction is effective April 3, 2008.

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FOR FURTHER INFORMATION CONTACT:

John F. Tarrant or Ross E. Poulsen, (202) 622-7790 (not a toll-free number).

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SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations that are the subject of this document are under section 1502 of the Internal Revenue Code.

Need for Correction

As published, final and temporary regulations (TD 9383) contain an error that may prove to be misleading and is in need of clarification.

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List of Subjects in 26 CFR Part 1

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Correction of Publication

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Accordingly,

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PART 1—INCOME TAXES

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

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Intercompany transactions (temporary).
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(c) * * *

(6) * * *

(ii) * * *

(C) * * *

(1) In general. Notwithstanding paragraph (c)(6)(ii)(A)(1), intercompany gain with respect to member stock is redetermined to be excluded from gross income to the extent that—

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LaNita Van Dyke,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).

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[FR Doc. E8-6883 Filed 4-2-08; 8:45 am]

BILLING CODE 4830-01-P