Internal Revenue Bulletin: 2005-23 |
June 6, 2005 |
Guidance Under Section 355(e); Recognition of Gain on Certain Distributions of Stock or Securities in Connection With an Acquisition; Correction
Table of Contents
This document corrects final regulations and removal of temporary regulations (T.D. 9198, 2005-18 I.R.B. 972), that were published in the Federal Register on Tuesday, April 19, 2005 (70 FR 20279) that relate to the recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition.
The final regulations and removal of temporary regulations (T.D. 9198), which is the subject of this correction are under section 355(e) of the Internal Revenue Code.
As published, the final regulations and removal of temporary regulations (T.D. 9198) contain errors that may prove to be misleading and are in need of clarification.
Accordingly, the publication of the final regulations and removal of temporary regulations (T.D. 9198), which was the subject of FR. Doc. 05-7811, is corrected as follows:
1. On page 20280, column 2, in the preamble, under the paragraph heading “New Safe Harbor for Acquisitions Before a Pro Rata Distribution”, line 9, the language “discussions regarding the acquisition” is corrected to read “discussions with the acquirer regarding a distribution”.
2. On page 20280, column 2, in the preamble, under the paragraph heading “New Safe Harbor for Acquisitions Before a Pro Rata Distribution”, lines 15 and 16, the language “prior to discussions regarding the acquisition and that the acquisition was” is corrected to read “prior to discussions regarding a distribution and that the acquisition was”.
Cynthia E. Grigsby,
Acting
Chief, Publications and Regulations Branch,
Legal Processing
Division,
Associate Chief Counsel
(Procedure
and Administration).
Note
(Filed by the Office of the Federal Register on May 16, 2005, 8:45 a.m., and published in the issue of the Federal Register for May 17, 2005, 70 F.R. 28211)
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