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TREAS/IRS

RIN: 1545-AM97

Publication ID: Fall 2008

Title: Outbound Transfers of Property to Foreign Corporations
Abstract: The income tax regulations under section 367(a) will be amended to reflect the changes made to that section by the Technical and Miscellaneous Corrections Act of 1988. Section 367(a)(5) now provides that a transfer of assets to a foreign corporation in an exchange described in section 361 is subject to section 367(a)(1), unless certain ownership requirements and other conditions are met. The regulations will provide guidance regarding the application of this section. The change in the statute was necessitated by the repeal of "General Utilities."
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 7805    26 USC 367

Legal Deadline:  None

Timetable: Action Date FR Cite NPRM  12/00/2008

Additional Information: REG-209006-89 (INTL-089-89) Drafting attorney: Daniel M. McCall (202) 622-3860 Reviewing attorney: Charles P. Besecky (202) 622-3860 CC: INTL
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Daniel M. McCall Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3860