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Regulatory Information
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2013-03-19
article
Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations
Rules and Regulations
D09002ee1bdca7974
D09002ee1bdca7a4a
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 final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. The text of these temporary regulations serves as the text of the proposed regulations (REG-132702- 10) published in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
78 FR 17053
https://www.govinfo.gov/app/details/FR-2013-03-19/2013-05696
2013-05696
fr19mr13-16
RIN 1545-BJ75
4830-01-P
TD 9615
https://www.govinfo.gov/app/details/FR-2013-03-19/2013-05696
https://www.govinfo.gov/content/pkg/FR-2013-03-19/html/2013-05696.htm
https://www.govinfo.gov/content/pkg/FR-2013-03-19/pdf/2013-05696.pdf
Income Taxes
Reporting and Recordkeeping Requirements
13 p.
17053
17065
78 FR 17053
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Code of Federal Regulations
Title 26 Part 602
26 CFR Part 602
Regulation Identification Number 1545-BJ75
RIN 1545-BJ75
Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations; Federal Register Vol. 78, Issue
RULE
2013-05696
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2013-03-19
TD 9615
4830-01-P
2013-05696
Final and temporary regulations.
This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. The text of these temporary regulations serves as the text of the proposed regulations (REG-132702- 10) published in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
Effective Date: The final and temporary regulations are effective on March 19, 2013.
Robert B. Williams, Jr., (202) 622- 3860 (not a toll-free number).
Income Taxes
Reporting and Recordkeeping Requirements
Indirect Stock Transfers and Coordination Rule Exceptions:
Transfers of Stock or Securities in Outbound Asset Reorganizations
,
www.regulations.gov
Federal Register
Vol. 78, no. 53
Office of the Federal Register, National Archives and Records Administration
2013-03-19
continuing
daily
deposited
born digital
301 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2013-03-19
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0042-1219
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https://www.govinfo.gov/app/details/FR-2013-03-19
https://www.govinfo.gov/content/pkg/FR-2013-03-19/pdf/FR-2013-03-19.pdf
https://www.govinfo.gov/content/pkg/FR-2013-03-19/xml/FR-2013-03-19.xml
fdlp
16777
17067
DGPO
2013-03-19
2023-04-30
FR-2013-03-19
machine generated
eng
FR
FR-2013-03-19
78
53