||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
Internal Revenue Service (IRS), Treasury.
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.
This correction is effective January 23, 2006.
FOR FURTHER INFORMATION CONTACT:
Christopher Trump (202) 622-3860 (not a toll-free number).
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.
* * * * *
Correction of Publication
Accordingly, 26 CFR Part 1 is corrected by making the following correcting
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
§1.367(b)-6 Effective dates and coordination rules.
(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,
Publications and Regulations Branch,
Legal Processing Division,
(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.
Internal Revenue Bulletin 2006-24
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