Internal Revenue Bulletin: 2011-35
August 29, 2011
Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction
Table of Contents
This document describes a correction to final regulations (T.D. 9475, 2010-4 I.R.B. 304) that were published on Friday, December 18, 2009 (74 FR 67053). The regulations provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction. This document also contains final regulations under section 358 that provide guidance regarding the determination of the basis of stock or securities in a reorganization described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction. This document also contains final regulations under section 1502 that govern reorganizations described in section 368(a)(1)(D) involving members of a consolidated group.
The final regulations (T.D. 9475) that are the subject of this document are under sections 358, 368 and 1502 of the Internal Revenue Code.
As published, the final regulations (T.D. 9475) contain an error that may prove to be misleading and is in need of clarification.
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Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Par. 2. Section 1.1502-13 is amended by adding paragraph (l)(6) to read as follows:
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(l) * * *
(6) Effective/applicability date. (i) In general. Paragraph (f)(7)(i) Example 4. applies to transactions occurring on or after December 18, 2009.
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LaNita Van Dyke,
Chief, Publications and
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on August 9, 2011, 8:45 a.m., and published in the issue of the Federal Register for August 10, 2011, 76 F.R. 49300)
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