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TREAS/IRS | RIN: 1545-BG96 | Publication ID: Fall 2008 |
Title: Regulations Implementing Notices 2006-85 and 2007-48 | |
Abstract: These regulations implement the rules announced in Notices 2006-85 (issued September 22, 2006) and 2007-48 (issued May 31, 2007). These notices announced that Treasury and the IRS would issue regulations under section 367(b) to address transactions where foreign or domestic corporations seek to avoid treating as a dividend the amount of property that a subsidiary transfers to its parent or its parent's shareholders in exchange for parent stock, which the subsidiary then uses to acquire the stock or assets of another corporation in a triangular reorganization. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Long-Term Actions |
Major: No | Unfunded Mandates: Undetermined |
CFR Citation: 26 CFR 1 26 CFR 1.367(b)-14T | |
Legal Authority: 26 USC 7805 26 USC 0367 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-136020-07 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 |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-BG97 | |
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 |