Skip to Content

Rule

Gain Recognition Agreements With Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; 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.

Start Preamble

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

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.

DATES:

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

SUPPLEMENTARY INFORMATION:

Background

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 1

End List of Subjects

Correction of Publication

Start Amendment Part

Accordingly,

End Amendment Part Start Part

PART 1—INCOME TAXES

End Part Start Amendment Part

End Amendment Part Start Authority

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

End Authority Start Amendment Part

End Amendment Part
Gain recognition agreement requirements.
* * * * *

(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.

* * * * *
Start Signature

Guy Traynor,

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

End Signature End Supplemental Information

[FR Doc. E9-4998 Filed 3-9-09; 8:45 am]

BILLING CODE 4830-01-P