This PDF is the current document as it appeared on Public Inspection on 07/02/2015 at 04:15 pm.
Internal Revenue Service (IRS), Treasury.
This document contains corrections to final and temporary regulations (TD 9722) that were published in the Federal Register on June 12, 2015 (80 FR 33402). The final and temporary regulations prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner.
This correction is effective on July 2, 2015 and applicable beginning June 12, 2015.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Kevin I. Babitz at (202) 317-6852 (not a toll free number).End Further Info End Preamble Start Supplemental Information
The final and temporary regulations (TD 9722) that are the subject of this correction are under sections 311(b), 336(a), and 337(d) of the Internal Revenue Code.
Need for Correction
As published, the final and temporary regulations (TD 9722) 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 1.337(d)-3T is amended by revising paragraphs (c)(2)(i) and (f)(2)(ii) to read as follows:End Amendment Part
(c) * * *
(2) * * * (i) In general. With respect to a Corporate Partner, Stock of the Corporate Partner includes the Corporate Partner's stock, or other equity interests, including options, warrants, and similar interests, in the Corporate Partner or a corporation that controls the Corporate Partner within the meaning of section 304(c), except that section 318(a)(1) and (3) shall not apply. Stock of the Corporate Partner also includes interests in any entity to the extent that the value of the interest is attributable to Stock of the Corporate Partner.
(f) * * *
(2) * * *
(ii) Is not distributed to the Corporate Partner or a corporation that controls the Corporate Partner within the meaning of section 304(c), except that section 318(a)(1) and (3) shall not apply.
Par 3. Section 1.732-1T paragraph (c)(5)(ii) is amended by removing the word “Nothwithstanding” and adding in its place the word “Notwithstanding”.End Amendment Part Start Signature
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-16674 Filed 7-2-15; 4:15 pm]
BILLING CODE 4830-01-P