These temporary and proposed
regulations under IRC § 367(a) provide rules for taxpayers to avoid
recognizing gain under a gain recognition agreement (GRA) if a new
GRA and notice statement are filed. The regulations also provide a
rule under which a taxpayer may reduce the basis in certain stock
to meet one of the requirements for terminating a GRA. These
regulations also revise an existing rule to facilitate electronic
filing. The revision requires that information that a taxpayer
currently would write on the face of its Federal income tax return
shall instead be attached as a separate schedule to its
return
This regulation is an
emergency submission because publication of the regulation is
planned for December 8, 2006. Because these are temporary and
proposed regulations, issuing the regulations by December 8, 2006
will help facilitate end-of-the-year transactions for taxpayers.
Chief Counsel International has received numerous requests from
taxpayers requesting prompt, immediately effective guidance in this
area. Treasury's General Counsel concurs that this submission
should be treated as an emergency.
REG-147144-06, Section
1.367(a)-8 revisions are a new collection.
$0
No
No
Uncollected
Uncollected
Uncollected
Uncollected
Daniel McCall 202
622-3860
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.