[Federal Register Volume 82, Number 170 (Tuesday, September 5, 2017)]
[Rules and Regulations]
[Page 41885]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-18691]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9814]
RIN 1545-BM95


Transfers of Certain Property by U.S. Persons to Partnerships 
With Related Foreign Partners; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correcting amendment.

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SUMMARY: This document contains corrections to the temporary 
regulations (T.D. 9814) that were published in the Federal Register on 
Thursday, January 19, 2017 (82 FR 7582). The regulations address 
transfers of appreciated property by United States persons to 
partnerships with foreign partners related to the transferor. The 
regulations override the rules providing for nonrecognition of gain on 
a contribution of property to a partnership in exchange for an interest 
in the partnership under section 721(a) of the Internal Revenue Code 
(Code) pursuant to section 721(c) unless the partnership adopts the 
remedial method and certain other requirements are satisfied.

DATES: These corrections are effective on September 5, 2017 and 
applicable on January 18, 2017.

FOR FURTHER INFORMATION CONTACT: Ronald M. Gootzeit, (202) 317-6937 
(not a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The temporary regulations that are the subject of this correction 
are under section 721(c) of the Code.

Need for Correction

    As published, the temporary regulations contain errors that may 
prove to be misleading and need to be clarified.

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 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 1.721(c)-1T is amended by revising paragraph 
(b)(10)(vi) to read as follows:


Sec.  1.721(c)-1T   Overview, definitions, and rules of general 
application (temporary).

* * * * *
    (b) * * *
    (10) * * *
    (vi) An allocation of partnership level ordinary income or loss 
described in Sec.  1.751-1(b)(3).
* * * * *


0
Par. 3. Section 1.721(c)-6T is amended by revising the last sentence of 
paragraph (d)(2) to read as follows:


Sec.  1.721(c)-6T   Procedural and reporting requirements (temporary).

* * * * *
    (d) * * *
    (2) * * * The partnership must also attach to its Form 1065 a 
Schedule K-1 (Form 1065) for each direct or indirect partner that is a 
related foreign person with respect to the U.S. transferor.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, Procedure and Administration.
[FR Doc. 2017-18691 Filed 9-1-17; 8:45 am]
 BILLING CODE 4830-01-P