Notice 99-43 announced modification of
the current rules under Temporary Regulation section 1.897-6T(a)(1)
regarding transfers, exchanges and other dispositions of U.S. real
property interests in nonrecognition transactions occurring after
June 18, 1980. The notice provided that, contrary to section
1.897-6T(a)(1), a foreign taxpayer will not recognize a gain under
Code 897(e) for an exchange described in Code section 368(a)(1)(E)
or (F), provided the taxpayer receives substantially identical
shares of the same domestic corporation with the same divided
rights, voting power, liquidation preferences, and convertibility
as the shares exchanged without any additional rights or
features.
US Code:
26
USC 897 Name of Law: Disposition of investment in United States
real property
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.