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TREAS/IRS

RIN: 1545-AK79

Publication ID: Spring 2009

Title: Nonrecognition of Corporate Distributions and Reorganizations Under the Foreign Investment in Real Property Tax Act
Abstract: These regulations will provide rules concerning the effect of certain distributions including dividends, redemptions, distributions pursuant to reorganizations, and liquidations on corporations and their shareholders under the Foreign Investment in Real Property Tax Act. The regulations will also provide rules for determining the extent to which nonrecognition would apply to certain transfers of real property interests and the extent to which certain reorganizations will be treated as sales of property at fair market value.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Final Rule Stage
Major: No	Unfunded Mandates: No
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 7805 26 USC 897

Legal Deadline: None

Timetable:

Action	Date	FR Cite
NPRM	05/05/1988	53 FR 16233
Hearing	03/01/1989	54 FR 1189
Final Action	12/00/2009

Additional Information: REG-209039-87 (INTL-491-87) Drafting attorney: Stephen J. Hawes (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: Stephen J. Hawes Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3860 Fax:202 622-4476 Email: stephen.j.hawes@irscounsel.treas.gov