[Federal Register Volume 75, Number 38 (Friday, February 26, 2010)]
[Rules and Regulations]
[Page 8796]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-3927]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9477]
RIN 1545-BI14
Use of Controlled Corporations To Avoid the Application of
Section 304; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendment.
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SUMMARY: This document contains corrections to final and temporary
regulations (TD 9477) that were published in the Federal Register on
Wednesday, December 30, 2009 (74 FR 69021) regarding certain
transactions that are subject to section 304 but that are entered into
with a principal purpose of avoiding the application of section 304 to
a corporation that is controlled by the issuing corporation in the
transaction, or with a principal purpose of avoiding the application of
section 304 to a corporation that controls the acquiring corporation in
the transaction.
DATES: These corrections are effective on February 26, 2010 and are
applicable on or after December 29, 2009.
FOR FURTHER INFORMATION CONTACT: Sean W. Mullaney, (202) 622-3860 (not
a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9477) that are the subject
of these corrections are under section 304 of the Internal Revenue
Code.
Need for Correction
As published, the final and temporary regulations (TD 9477) contain
an error that may prove to be misleading and are in need of
clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Correction of Publication
0
Accordingly, 26 CFR part 1 is corrected by making the following
correcting amendments:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
0
Par. 2. Section 1.304-4T is amended by revising paragraph (e) to read
as follows:
Sec. 1.304-4T Special rule for the use of related corporations to
avoid the application of section 304 (temporary).
* * * * *
(e) Expiration date. This section expires on or before December 28,
2012.
Diane Williams,
Federal Register Liaison, Publications and Regulations Branch, Legal
Processing Division, Associate Chief Counsel (Procedure and
Administration).
[FR Doc. 2010-3927 Filed 2-25-10; 8:45 am]
BILLING CODE 4830-01-P