[Federal Register Volume 71, Number 94 (Tuesday, May 16, 2006)]
[Rules and Regulations]
[Pages 28266-28267]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 06-4533]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9243]
RIN 1545-BA65


Revision of Income Tax Regulations Under Sections 367, 884, and 
6038B Dealing With Statutory Mergers or Consolidations Under Section 
368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance 
Necessary To Facilitate Business Electronic Filing Under Section 6038B; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains a correction to final regulations (TD 
9243), that was published in the Federal Register on Thursday, January 
26, 2006 (71 FR 4276). This final regulation amends the income tax 
regulations under various provisions of the Internal Revenue Code to 
account for statutory mergers and consolidations.

DATES: This correction is effective January 23, 2006.

FOR FURTHER INFORMATION CONTACT: Christopher Trump (202) 622-3860 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulation (TD 9243) that is the subject of this 
correction is under section 367 of the Internal Revenue Code.

Need for Correction

    As published, TD 9243 contains an error that may prove to be 
misleading and is in need of clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

0
Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

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


Sec.  1.367(b)-6  [Corrected]

0
Par. 2. Section 1.367(b)-6 is amended by removing the third sentence of

[[Page 28267]]

paragraph (a)(1) and adding the following sentence in its place to read 
as follows:


Sec.  1.367(b)-6  Effective dates and coordination rules.

    (a) * * *
    (1) * * * Section 1.367(b)-4(b)(1)(ii) applies to all triangular 
reorganizations and reorganizations described in section 368(a)(1)(G) 
and (a)(2)(D) occurring on or after January 23, 2006, although 
taxpayers may apply Sec.  1.367(b)-4(b)(1)(ii) to triangular B 
reorganizations occurring on or after February 23, 2000, that is not 
closed by the period of limitations if done consistently with respect 
to all such triangular B reorganizations.* * *
* * * * *

Guy R. Traynor,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedures and Administration).
[FR Doc. 06-4533 Filed 5-15-06; 8:45 am]
BILLING CODE 4830-01-P