[Federal Register Volume 66, Number 9 (Friday, January 12, 2001)]
[Rules and Regulations]
[Pages 2821-2822]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-489]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 7

[TD 8938]


Requirements Relating to Certain Exchanges Involving a Foreign 
Corporation

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Removal of temporary regulations.

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SUMMARY: This document removes temporary regulations under section 
367(c) that are no longer necessary and, as a result, may be 
misleading.

DATES: Effective Date: January 12, 2001.

FOR FURTHER INFORMATION CONTACT: Mark D. Harris at (202) 622-3860 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    On December 30, 1977, the IRS and Treasury published in the Federal 
Register proposed regulations (42 FR 65204) and temporary regulations 
(42 FR 65152) under section 367(c) of the Internal Revenue Code. The 
principal purpose of these regulations, Secs. 7.367(c)-1 and 7.367(c)-
2, was to distinguish between the treatment of transfers described in 
section 367(c) before and after the enactment of the Tax Reform Act of 
1976 (the Act) (90 Stat. 1634). Before enactment of the Act, transfers 
described in section 367(c) were subject to a ruling requirement. After 
enactment of the Act, transfers described in section 367(c) were within 
the scope of Secs. 7.367(b)-1 through 7.367(b)-12. In light of the 
substantial time that has passed since enactment of the Act and, 
moreover, in light of the fact that Secs. 1.367(b)-1 through 1.367(b)-6 
have substantially superceded Secs. 7.367(b)-1 through 7.367(b)-12, 
Secs. 7.367(c)-1 and 7.367(c)-2 are no longer necessary and may be 
misleading.

    Accordingly, this document removes Secs. 7.367(c)-1 and 7.367(c)-2.

List of Subjects in 26 CFR Part 7

    Income taxes, Reporting and recordkeeping requirements.

Removal of Temporary Regulations

    Accordingly, under the authority of 26 U.S.C. 7805, 26 CFR part 7 
is amended as follows:

PART 7--TEMPORARY INCOME TAX REGULATIONS UNDER THE TAX REFORM ACT 
OF 1976

    Paragraph 1. The authority citation for part 7 continues to read in 
part as follows:

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

[[Page 2822]]

Secs. 7.367(c)-1 and 7.367(c)-2  [Amended]

    Par. 2. Sections 7.367(c)-1 and 7.367(c)-2 are removed.

Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.
    Approved: December 28, 2000.
Jonathan Talisman,
Assistant Secretary of the Treasury.
[FR Doc. 01-489 Filed 1-11-01; 8:45 am]
BILLING CODE 4830-01-U