[Federal Register Volume 75, Number 38 (Friday, February 26, 2010)]
[Rules and Regulations]
[Page 8796]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-3927]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9477]
RIN 1545-BI14


Use of Controlled Corporations To Avoid the Application of 
Section 304; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9477) that were published in the Federal Register on 
Wednesday, December 30, 2009 (74 FR 69021) regarding certain 
transactions that are subject to section 304 but that are entered into 
with a principal purpose of avoiding the application of section 304 to 
a corporation that is controlled by the issuing corporation in the 
transaction, or with a principal purpose of avoiding the application of 
section 304 to a corporation that controls the acquiring corporation in 
the transaction.

DATES: These corrections are effective on February 26, 2010 and are 
applicable on or after December 29, 2009.

FOR FURTHER INFORMATION CONTACT: Sean W. Mullaney, (202) 622-3860 (not 
a toll free number).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations (TD 9477) that are the subject 
of these corrections are under section 304 of the Internal Revenue 
Code.

Need for Correction

    As published, the final and temporary regulations (TD 9477) contain 
an error that may prove to be misleading and are 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 * * *


0
Par. 2. Section 1.304-4T is amended by revising paragraph (e) to read 
as follows:


Sec.  1.304-4T  Special rule for the use of related corporations to 
avoid the application of section 304 (temporary).

* * * * *
    (e) Expiration date. This section expires on or before December 28, 
2012.

Diane Williams,
Federal Register Liaison, Publications and Regulations Branch, Legal 
Processing Division, Associate Chief Counsel (Procedure and 
Administration).
[FR Doc. 2010-3927 Filed 2-25-10; 8:45 am]
BILLING CODE 4830-01-P