Internal Revenue Service (IRS), Treasury.
This document describes a correction to final regulations (TD 9475) that were published on Friday, December 18, 2009 (74 FR 67053). The regulations provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction. This document also contains final regulations under section 358 that provide guidance regarding the determination of the basis of stock or securities in a reorganization described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction. This document also contains final regulations under section 1502 that govern reorganizations described in section 368(a)(1)(D) involving members of a consolidated group.
This correction is effective on August 10, 2011 and is applicable on December 18, 2009.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Bruce A. Decker, (202) 622-7790 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations (TD 9475) that are the subject of this document are under sections 358, 368 and 1502 of the Internal Revenue Code.
Need for Correction
As published, the final regulations (TD 9475) contain 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 Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:Start Part
PART 1—INCOME TAXESEnd Part Start Amendment Part
End Amendment Part Start Amendment Part
End Amendment Part
(l) * * *
(6) Effective/applicability date. (i) In general. Paragraph (f)(7)(i) Example 4. applies to transactions occurring on or after December 18, 2009.
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2011-20224 Filed 8-9-11; 8:45 am]
BILLING CODE 4830-01-P