[Federal Register Volume 66, Number 9 (Friday, January 12, 2001)]
[Proposed Rules]
[Page 2856]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-490]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 7

[LR-230-76]


Requirements Relating to Certain Exchanges Involving a Foreign 
Corporation

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed regulations.

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SUMMARY: This document withdraws proposed regulations under section 
367(c). The proposed regulations correspond to temporary regulations 
that are also being removed in this issue of the Federal Register. The 
temporary regulations are being removed because they are no longer 
necessary and, as a result, may be misleading.

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have substantially superceded Secs. 7.367(b)-1 through 7.367(b)-12, 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, the IRS and Treasury are removing temporary 
regulations Secs. 7.367(c)-1 and 7.367(c)-2 in this issue of the 
Federal Register. Correspondingly, this document removes proposed 
regulations Secs. 7.367(c)-1 and 7.367(c)-2.

List of Subjects in 26 CFR Part 7

    Income taxes, Reporting and recordkeeping requirements.

Withdrawal of Proposed Amendments to the Regulations

    Accordingly, under the authority of 26 U.S.C. 7805, proposed 
regulations under 26 CFR part 7 relating to Secs. 7.367(c)-1 and 
7.367(c)-2, published December 30, 1977 (42 FR 65204), are withdrawn.

Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.
[FR Doc. 01-490 Filed 1-11-01; 8:45 am]
BILLING CODE 4830-01-U