Internal Revenue Service (IRS), Treasury.
This document contains a correction to final regulations (TD 9446) that were published in the Federal Register on Wednesday, February 11, 2009 (74 FR 6952) under section 367(a) of the Internal Revenue Code concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations.
This correction is effective March 10, 2009, and is applicable on February 11, 2009.Start Further Info
FOR FURTHER INFORMATION CONTACT:
S. James Hawes, (202) 622-3860 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations that are the subject of this document are under sections 338 and 367 of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9446) contains an error that may prove to be misleading and is in need of clarification.Start List of Subjects
List of Subjects in 26 CFR Part 1End List of Subjects
Correction of PublicationStart Amendment Part
Accordingly,End Amendment Part Start Part
PART 1—INCOME TAXESEnd Part Start Amendment Part
End Amendment Part Start Amendment Part
End Amendment Part
(k) * * *
(3) * * * A disposition of the transferred stock or securities pursuant to an exchange to which section 351, 354 (but only in a reorganization described in section 368(a)(1)(B)), or 721 applies, shall not constitute a triggering event if the U.S. transferor enters in to a new gain recognition agreement that provides that the dispositions described in paragraphs (k)(3)(i) and (ii) of this section shall constitute triggering events for purposes of the new gain recognition agreement.
Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. E9-4998 Filed 3-9-09; 8:45 am]
BILLING CODE 4830-01-P