Federal Register: July 28, 2010 (Volume 75, Number 144)
DOCID: fr28jy10-7 FR Doc 2010-18270
DEPARTMENT OF THE TREASURY
Internal Revenue Service
CFR Citation: 26 CFR Part 1
RIN ID: RIN 1545-BG03
TD ID: [TD 9487]
DOCUMENT ACTION: Correcting amendment.
Build-In Gains and Losses Under Section 382(h); Correction
DATES: This correction is effective on July 28, 2010, and is applicable on June 16, 2010.
This document contains correcting amends to IRS' regulations providing guidance regarding the treatment of prepaid income under the builtin gain provisions of section 382(h). These errors were made when the agency published final regulations (TD 9487) in the Federal Register on Wednesday, June 16, 2010 (75 FR 33990).
Build-in Gains and Losses Under Section 382(h); Correction
The final regulations (TD 9487) that are the subject of this document are under section 382 of the Internal Revenue Code. Need for Correction
As published, the final regulations (TD 9487) contain errors 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
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
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 1.3822T is amended by revising the headings of paragraph (h)(4)(vii)(A) and paragraph (h)(4)(x)(J) to read as follows: Sec. 1.3822T Definition of ownership change under section 382, as amended by the tax Reform Act of 1986 (temporary).
* * * * *
(h) * * *
(4) * * *
(vii) * * *
(A) Right or obligation to issue stock. * * *
* * * * *
(x) * * *
(J) Title 11 or similar case. * * *
* * * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 201018270 Filed 72710; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT
Keith E. Stanley, (202) 622-7750 (not a tollfree number).