Internal Revenue Bulletin: 2006-24
June 12, 2006
Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction
Table of Contents
This document contains a correction to final regulations (T.D. 9243, 2006-8 I.R.B. 475), that was published in the Federal Register on Thursday, January 26, 2006 (71 FR 4276). This final regulation amends the income tax regulations under various provisions of the Internal Revenue Code to account for statutory mergers and consolidations.
The final regulation (T.D. 9243) that is the subject of this correction is under section 367 of the Internal Revenue Code.
As published, T.D. 9243 contains an error that may prove to be misleading and is in need of clarification.
* * * * *
Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendments:
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 USC 7805 * * *
Par. 2. Section 1.367(b)-6 is amended by removing the third sentence of paragraph (a) (1) and adding the following sentence in its place to read as follows:
(a) * * *
(1) * * * Section 1.367(b)-4(b)(1)(ii) applies to all triangular reorganizations and reorganizations described in section 368(a)(1)(G) and (a)(2)(D) occurring on or after January 23, 2006, although taxpayers may apply §1.367(b)-4(b)(1)(ii) to triangular B reorganizations occurring on or after February 23, 2000, that is not closed by the period of limitations if done consistently with respect to all such triangular B reorganizations. * * *
* * * * *
Guy R. Traynor,
Chief, Publications and Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on May 15, 2006, 8:45 a.m., and published in the issue of the Federal Register for May 16, 2006, 71 F.R. 28266)
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