[Federal Register Volume 85, Number 32 (Tuesday, February 18, 2020)]
[Rules and Regulations]
[Pages 8725-8726]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-02654]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9891]
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 regulations; correction.

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SUMMARY: This document contains a correction to final regulations (T.D. 
9891) that were published in the Federal Register on Thursday, January 
23, 2020. Treasury Decision 9891 contains final regulations that 
provide guidance applicable to transfers of appreciated property by 
U.S. persons to partnerships with foreign partners related to the 
transferor.

DATES: 
    Effective date: These regulations are effective February 18, 2020 
and applicable January 23, 2020.
    Applicability dates: For dates of applicability, see Sec.  
1.721(c)-6.

FOR FURTHER INFORMATION CONTACT: Chadwick Rowland, (202) 317-6937 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9891) that are the subject of this 
correction are issued under section 721 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9891), contains errors that 
may prove to be misleading and are in need of clarification.

Correction to Publication

    Accordingly, the final regulations (TD 9891), that are the subject 
of FR Doc. 2020-00383, in the issue of January 23, 2020 (85 FR 3833), 
are corrected as follows:

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1. On page 3834, in the third column, in the second and third sentence 
of the second full paragraph, ``PRS1 wholly owns a domestic corporation 
(UST). In Year 1, UST forms a new partnership (PRS2); as part of the 
formation, UST contributes section 721(c) property (as defined in Sec.  
1.721(c)-1(b)(15)) in return for a 90 percent interest in PRS2's 
capital and profits, and a U.S. individual (unrelated to UST) 
contributes cash in return for the remaining interest in PRS2's capital 
and profits.'' is corrected to read ``PRS1 wholly owns a domestic 
corporation (UST) and holds 90 percent of the interests in a lower tier 
partnership's (PRS2) capital and profits. In Year 1, UST and PRS2 form 
a new partnership (PRS3); as part of the formation, UST contributes 
section 721(c) property (as defined in Sec.  1.721(c)-1(b)(15)) in 
return for a 90 percent interest in PRS3's capital and profits, and a 
U.S. individual (unrelated to UST) contributes cash in return for the 
remaining interest in PRS3's capital and profits''.
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2. On page 3834, in the third column, the second line of the fourth 
partial paragraph, ``PRS2'' is corrected to read ``PRS3''.
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3. On page 3835, in the first column, the second line from the bottom 
of the first full paragraph, ``consequence, PRS2'' is corrected to read 
``consequence, PRS3''.

[[Page 8726]]

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4. On page 3835, in the third column, the third line from the bottom of 
the page, ``filed before March 17'' is corrected to read ``filed before 
July 17.''

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-02654 Filed 2-14-20; 8:45 am]
 BILLING CODE 4830-01-P