[Federal Register Volume 76, Number 154 (Wednesday, August 10, 2011)]
[Rules and Regulations]
[Page 49300]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-20224]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9475]
RIN 1545-BF83


Corporate Reorganizations; Distributions Under Sections 
368(a)(1)(D) and 354(b)(1)(B); Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document describes a correction to final regulations (TD 
9475) that were published on Friday, December 18, 2009 (74 FR 67053). 
The regulations provide guidance regarding the qualification of certain 
transactions as reorganizations described in section 368(a)(1)(D) where 
no stock and/or securities of the acquiring corporation is issued and 
distributed in the transaction. This document also contains final 
regulations under section 358 that provide guidance regarding the 
determination of the basis of stock or securities in a reorganization 
described in section 368(a)(1)(D) where no stock and/or securities of 
the acquiring corporation is issued and distributed in the transaction. 
This document also contains final regulations under section 1502 that 
govern reorganizations described in section 368(a)(1)(D) involving 
members of a consolidated group.

DATES: This correction is effective on August 10, 2011 and is 
applicable on December 18, 2009.

FOR FURTHER INFORMATION CONTACT: Bruce A. Decker, (202) 622-7790 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9475) that are the subject of this 
document are under sections 358, 368 and 1502 of the Internal Revenue 
Code.

Need for Correction

    As published, the final regulations (TD 9475) contain 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

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

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 1.1502-13 is amended by adding paragraph (l)(6) to read 
as follows:


Sec.  1.1502-13  Intercompany transactions.

* * * * *
    (l) * * *
    (6) Effective/applicability date. (i) In general. Paragraph 
(f)(7)(i) Example 4. applies to transactions occurring on or after 
December 18, 2009.
    (ii) [Reserved]
* * * * *

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2011-20224 Filed 8-9-11; 8:45 am]
BILLING CODE 4830-01-P