United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2000_register executive 2010-09-23 article Part III Proposed Rules D09002ee1c81ebd63 D09002ee1c81ebeb0 United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains proposed regulations addressing transactions described in section 367(b) of the Internal Revenue Code (section 367(b) transactions). A section 367(b) transaction includes a corporate reorganization, liquidation, or division involving one or more foreign corporations. The proposed regulations address the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a section 367(b) transaction. The proposed regulations also address the allocation of certain tax attributes when a corporation distributes stock of another corporation in a section 367(b) transaction. This document also provides notice of a public hearing on the proposed regulations. 65 FR 69138 https://www.govinfo.gov/app/details/FR-2000-11-15/00-28950 00-28950 fr15no00-43 RIN 1545-AX65 4830-01-U REG-116050-99 https://www.govinfo.gov/app/details/FR-2000-11-15/00-28950 https://www.govinfo.gov/content/pkg/FR-2000-11-15/html/00-28950.htm https://www.govinfo.gov/content/pkg/FR-2000-11-15/pdf/00-28950.pdf Income Taxes Reporting and Recordkeeping Requirements 45 p. 69138 69182 65 FR 69138 Title 26 Part 1 26 CFR Part 1 RIN 1545-AX65 Stock Transfer Rules: Carryover of Earnings and Taxes; Federal Register Vol. 65, Issue PRORULE 00-28950 III DEPARTMENT OF THE TREASURY Internal Revenue Service 2001-03-13 REG-116050-99 4830-01-U 00-28950 Notice of proposed rulemaking and notice of public hearing.

This document contains proposed regulations addressing transactions described in section 367(b) of the Internal Revenue Code (section 367(b) transactions). A section 367(b) transaction includes a corporate reorganization, liquidation, or division involving one or more foreign corporations. The proposed regulations address the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a section 367(b) transaction. The proposed regulations also address the allocation of certain tax attributes when a corporation distributes stock of another corporation in a section 367(b) transaction. This document also provides notice of a public hearing on the proposed regulations.

Written or electronic comments and requests to speak (with outlines of oral comments) at a public hearing scheduled for March 13, 2001 must be received by February 20, 2001. Concerning the proposed regulations, Anne O'Connell Devereaux, at (202) 622-3850; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, Guy Traynor, at (202) 622-7180 (not toll-free numbers). Income Taxes Reporting and Recordkeeping Requirements Income taxes: Stock transfer rules Earnings and taxes carryover, http://www.irs.gov/tax_regs/regslist.html Vol. 65, no. 221 Office of the Federal Register, National Archives and Records Administration 2000-11-15 continuing daily deposited born digital 376 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2000-11-15 P0b002ee1809ec6d3 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr15no00 https://www.govinfo.gov/app/details/FR-2000-11-15 https://www.govinfo.gov/content/pkg/FR-2000-11-15/pdf/FR-2000-11-15.pdf https://www.govinfo.gov/content/pkg/FR-2000-11-15/xml/FR-2000-11-15.xml fdlp 68871 69236 DGPO 2010-09-23 2024-06-08 FR-2000-11-15 machine generated eng FR FR-2000-11-15 65 221