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LEXSEE TD 8817
Treasury Decisions
Copyright 2007 LexisNexis Group, All Rights Reserved
Rules and Regulations
DEPARTMENT OF THE TREASURY
Internal Revenue Service (IRS)
26 CFR Part 1
64 FR 15686; RIN 1545-AV70
Notice of Certain Transfers to Foreign Partnerships and Foreign Corporations; Correction
T.D. 8817
DATE: April 1, 1999
ACTION: Correction to final regulations.
SUMMARY: This document contains corrections to final income tax regulations that were published in the Federal
Register on Friday, February 5, 1999 (64 FR 5713) relating to certain transfers to foreign partnerships and corporations
by U.S. persons.
DATES: This correction is effective February 5, 1999.
FOR FURTHER INFORMATION CONTACT: Eliana Dolgoff (202)622-3860 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the subject of this correction are under section 6038B of the Internal Revenue Code.
Need for Correction
As published, the final regulations contain errors that may prove to be misleading and are in need of clarification.
Correction of Publication
Accordingly, the publication of the final regulations (TD 8817), that were the subject of FR Doc. 99-2798, is
corrected as follows:
Page 2
T.D. 8817
§ 1.6038B-1 -- [Corrected]
1. On page 5715, column 1, amendatory instruction Par. 2, instruction 2. is corrected to read "2. In paragraph
(b)(1)(i), the first sentence is removed and two new sentences are added in its place.".
1a. On page 5715, column 1, § 1.6038B-1(b)(1)(i), lines 4 through 7, the language "paragraph (b)(2) of this section,
or cash, which is subject to special rules contained in paragraph (b)(3) of this section, any U.S. person that makes a" is
corrected to read "paragraph (b)(2) of this section, any U.S. person that makes a". 1b. On page 5715, column 1, in §
1.6038B-1(b)(1)(i), a new sentence is added after the first sentence to read "For special rules regarding cash transfers
made in tax years beginning after February 5, 1999, see paragraphs (b)(3) and (g) of this section.".
2. On page 5715, column 1, § 1.6038B-1(b)(3) introductory text, line 2, the language "foreign corporation must
report the" is corrected to read "foreign corporation in a transfer described in section 6038B(a)(1)(A) must report the".
3. On page 5715, column 2, § 1.6038B-1(c), line 6, the language "section 6038B(a)(1)(A) (including cash" is
corrected to read "section 6038B(a)(1)(A) (including cash transferred in taxable years beginning after February 5,
1999,".
4. On page 5715, column 2, § 1.6038B-1(g), lines 3 through 8, the language "July 20, 1998, except that the first
sentence of paragraph (b)(1)(i), paragraph (b)(3), and the first sentence of paragraph (c) apply to transfers occurring in
taxable years beginning after February 5, 1999. See § 1.6038B-" is corrected to read "July 20, 1998, except that
transfers of cash made in taxable years beginning on or before February 5, 1999 are not required to be reported under
section 6038B. See § 1.6038B-".
§ 1.6038B-2 -- [Corrected]
5. On page 5717, column 2, § 1.6038B-2(j)(1)(ii) line 1, the language, "Filing a Form 926 with the" is corrected to
read "Filing a Form 926 (modified to reflect that the transferee is a partnership, not a corporation) with the".
Cynthia E. Grigsby,
Chief, Regulations Unit, Assistant Chief Counsel (Corporate).
[FR Doc. 99-7793 Filed 3-31-99; 8:45 am]
BILLING CODE 4830-01-U
11059F
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