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2018-02-02
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Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations
Rules and Regulations
D09002ee1bdc1e3af
D09002ee1bdc1e432
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 regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also finalize modifications to the exception to the coordination rule for section 351 exchanges so that it is consistent with the remaining asset reorganization exception. In addition, the regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements. Finally, the regulations finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. These regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges.
81 FR 15159
https://www.govinfo.gov/app/details/FR-2016-03-22/2016-06404
2016-06404
fr22mr16-6
RIN 1545-BJ74
4830-01-P
TD 9760
https://www.govinfo.gov/app/details/FR-2016-03-22/2016-06404
https://www.govinfo.gov/content/pkg/FR-2016-03-22/html/2016-06404.htm
https://www.govinfo.gov/content/pkg/FR-2016-03-22/pdf/2016-06404.pdf
Income Taxes
Reporting and Recordkeeping Requirements
12 p.
15159
15170
81 FR 15159
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Regulation Identification Number 1545-BJ74
RIN 1545-BJ74
Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations; Federal Register Vol. 81, Issue
RULE
2016-06404
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2016-03-22
TD 9760
4830-01-P
2016-06404
Final regulations and removal of temporary regulations.
This document contains final regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also finalize modifications to the exception to the coordination rule for section 351 exchanges so that it is consistent with the remaining asset reorganization exception. In addition, the regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements. Finally, the regulations finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. These regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges.
Effective Date: These regulations are effective on March 22, 2016.
Joshua G. Rabon at (202) 317-6937 (not a toll-free number).
Income Taxes
Reporting and Recordkeeping Requirements
Indirect Stock Transfers and the Coordination Rule Expectation:
Transfers of Stock or Securities in Outbound Asset Reorganizations
,
Federal Register
Vol. 81, no. 55
Office of the Federal Register, National Archives and Records Administration
2016-03-22
continuing
daily
deposited
born digital
274 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2016-03-22
P0b002ee19834ba89
0097-6326
0042-1219
0364-1406
769-004-00000-9
000582072
f:fr22mr16
https://www.govinfo.gov/app/details/FR-2016-03-22
https://www.govinfo.gov/content/pkg/FR-2016-03-22/pdf/FR-2016-03-22.pdf
https://www.govinfo.gov/content/pkg/FR-2016-03-22/xml/FR-2016-03-22.xml
fdlp
15153
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DGPO
2018-02-02
2023-04-29
FR-2016-03-22
machine generated
eng
FR
FR-2016-03-22
81
55