This PDF is the current document as it appeared on Public Inspection on 01/02/2015 at 08:45 am.
Internal Revenue Service (IRS), Treasury.Start Printed Page 167
This document contains corrections to final regulations (TD 9704) that were published in the Federal Register on Wednesday, November 19, 2014 (79 FR 68763) relating to the consequences to U.S. and foreign persons for failing to file gain recognition agreements (GRAs) or related documents, or to satisfy other reporting obligations, associated with certain transfers of property to foreign corporations in nonrecognition exchanges.
This correction is effective on January 5, 2015, and is applicable beginning November 19, 2014.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Shane M. McCarrick at (202) 317-6937 (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 367 and 6038B of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9704) contain errors that may prove to be misleading and are in need of clarification.Start List of Subjects
List of Subjects in 26 CFR Part 1
- Income taxes
- Reporting and recordkeeping requirements
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:Start Part
PART 1—INCOME TAXESEnd Part Start Amendment Part
Paragraph 1. The authority citation for part 1 continues to read in part as follows:End Amendment Part Start Amendment Part
Par. 2. Section 1.367(a)-8 is amended by revising the paragraph headings for paragraphs (r)(1) and (r)(1)(i) to read as follows:End Amendment Part
(r) * * * (1) General rule—(i) Transfers occurring on or after March 13, 2009; relief for certain failures that are not willful. * * *
Par. 3. Section 1.367(e)-2 is amended by revising paragraph (e)(4)(i) introductory text to read as follows:End Amendment Part
(e) * * *
(4) * * *
(i) General rule. For purposes of this section and except as provided in paragraph (b)(2)(i)(D) or (f) of this section, a failure to comply includes—
Par. 4. Section 1.6038B-1 is amended by revising paragraph (g)(6) to read as follows:End Amendment Part
(g) * * *
(6) The second sentence of paragraph (b)(1)(i) and paragraphs (b)(2)(i)(B)(1), (b)(2)(iii), (b)(2)(iv), (c), (e)(4), (f)(2)(iii), and (f)(2)(iv) of this section will apply to transfers for which documents are required to be filed on or after November 19, 2014, as well as to transfers that are the subject of requests for relief submitted on or after November 19, 2014. The second sentence of paragraph (b)(1)(i) and paragraphs (b)(2)(i)(B)(1), (b)(2)(iii), (b)(2)(iv), (c), and (f)(2)(iii) of this section will also apply to any transfer that is the subject of a request for relief submitted pursuant to § 1.367(a)-8(r)(3).
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2014-30811 Filed 1-2-15; 8:45 am]
BILLING CODE 4830-01-P