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TD ID: [TD 9383]
RIN ID: RIN 1545-BH21
SUBJECT CATEGORY: Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction
DOCUMENT SUMMARY: This document contains a correction to final and temporary regulations (TD 9383) that were published in the Federal Register on Friday, March 7, 2008 (73 FR 12265). Concerning the treatment of certain intercompany gain with respect to consolidated group member stock. These amendments provide for the redetermination of an intercompany gain as excluded from gross income in certain member stock transactions. These regulations affect corporations filing consolidated returns.
SUMMARY: Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction,
The final and temporary regulations that are the subject of this document are under section 1502 of the Internal Revenue Code. Need for Correction
As published, final and temporary regulations (TD 9383) contain an error that may prove to be misleading and is in need of clarification. List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements. Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:
PART 1INCOME TAXES
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.150213T is amended by revising the introductory text of paragraph (c)(6)(ii)(C)(1) to read as follows:
Sec. 1.150213T Intercompany transactions (temporary).
* * * * *
(c) * * *
(6) * * *
(ii) * * *
(C) * * *
(1) In general. Notwithstanding paragraph (c)(6)(ii)(A)(1),
intercompany gain with respect to member stock is redetermined to be excluded from gross income to the extent that
* * * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E86883 Filed 4208; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT John F. Tarrant or Ross E. Poulsen, (202) 6227790 (not a tollfree number).
14 CFR Part 39 40 CFR Part 52 14 CFR Part 71 33 CFR Part 165 26 CFR Part 1 50 CFR Part 679 40 CFR Part 180 47 CFR Part 73 33 CFR Part 117 50 CFR Part 17 44 CFR Part 67 50 CFR Part 648 14 CFR Part 97 33 CFR Part 100 40 CFR Part 63 26 CFR Part 301 50 CFR Part 622 39 CFR Part 111 40 CFR Part 300 50 CFR Part 660 44 CFR Part 65 40 CFR Parts 52 and 81 40 CFR Part 271 47 CFR Part 64 14 CFR Part 23 14 CFR Part 25 21 CFR Part 522 50 CFR Part 665 47 CFR Part 76 27 CFR Part 9