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TREAS/IRS | RIN: 1545-BO01 | Publication ID: Spring 2018 |
Title: Tax on Property Owned by a C Corporation That Becomes Property of a RIC or REIT | |
Abstract:
Temporary and proposed regulations under section 337(d) generally treat a C corporation that engages in a conversion transaction involving a REIT within the ten-year period following a section 355 distribution as if the C corporation had elected deemed sale treatment. The final regulations also will cause a REIT that engages in a section 355 distribution within the ten-year period following a conversion transaction for which a deemed sale election has not already been made to recognize any remaining unrealized built-in gains and losses on the property that became property of the REIT. These proposed regulations would amend the temporary regulations to address situations where an inappropriate amount of gain may be recognized as a result of the predecessor-successor rule in the temporary and proposed regulations. |
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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: No |
EO 13771 Designation: Deregulatory | |
CFR Citation: 26 CFR 1.337(d)-7 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 337(d) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-113943-17 (NPRM) Drafter attorney: Austin Diamond-Jones (202) 317-5363 Reviewer attorney: Lisa A. Fuller (202) 317-7700 Treasury attorney: Brett York (202) 622-1285 CC:CORP | |
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: Austin Diamond-Jones Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-5363 Email: austin.m.diamond-jones@irscounsel.treas.gov |