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TREAS/IRS | RIN: 1545-BG09 | Publication ID: Spring 2009 |
Title: Gain Recognition Agreements With Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations | |
Abstract: These regulations will finalize section 1.367(a)-8T. The regulations will provide rules describing how U.S. taxpayers enter into gain recognition agreements in connection with the transfer of stock or securities to foreign corporations. The regulations will also clarify the effect that certain transactions have on existing gain recognition agreements. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Completed Actions |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.367(a)-3T 26 CFR 1.367(a)-8T | |
Legal Authority: 26 USC 7805 26 USC 0367 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-147144-06 Drafting Attorney: Stephen J. Hawes (202) 622-3860 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 |