Announcement 2010-7

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Internal Revenue Bulletin:

2010-6 February 8, 2010

Announcement 2010-7

Modification to Consolidated Return Regulation Permitting an Election to Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization


Contents


AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

Summary:

This document contains a correction to temporary regulations (T.D. 9458, 2009-43 I.R.B. 547), which were published in the Federal Register on Friday, September 4, 2009 (74 FR 45757) relating to modification to consolidated return regulation permitting an election to treat a liquidation of a target, followed by a recontribution to a new target, as a cross-chain reorganization.


DATES:

The correction is effective on January 13, 2010 and is applicable beginning September 4, 2009.


FOR FURTHER INFORMATION CONTACT:

Guy Traynor at (202) 622-3693 (not a toll-free number).

SUPPLEMENTARY INFORATION:

Background

The temporary regulation that is the subject to this correction is under section 1502 of the Internal Revenue Code.


Need for Correction

As published, temporary regulations (T.D. 9458), contains an error which 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 amendment.


PART 1—INCOME TAXES

Paragraph 1. The authority for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

Par. 2. Paragraph (f)(5)(ii)(G) needs to be added following paragraph (f)(5)(ii)(F)(3), to read as follows:


§1.1502-13T Intercompany transactions (temporary).

* * * * *

(f) * * *

(5) * * *

(ii) * * *

(G) Expiration date. Paragraphs (f)(5)(ii)(B), (B)(1), (B)(2) and (F)(1), (2), and (3) of this section will expire on September 3, 2012.

* * * * *

Guy R. Traynor,
Federal Register Liaison,
Publications & Regulations Branch,
Legal Processing
Division,
Associate Chief Counsel
(Procedure & Administration).

Note

(Filed by the Office of the Federal Register on January 12, 2010, 8:45 a.m., and published in the issue of the Federal Register for January 13, 2010, 75 F.R. 1704)

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