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RuleSignificant2017-004972017-01-24

Treatment of Certain Interests in Corporations as Stock or Indebtedness; Correction.

Treasury Department, Internal Revenue Service

Abstract

This document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 (81 FR 72858). The regulations relate to the determination of whether an interest in a corporation is treated as stock or indebtedness for all purposes of the Internal Revenue Code.

Action & Dates

Action
Final and temporary regulations; correction.
Dates
These corrections are effective on January 23, 2017, and applicable October 21, 2016.
Effective Date
2017-01-23

CFR References

Document Excerpt

Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 9790] RIN 1545-BN40 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regulations; correction. SUMMARY: This document contains corrections to the final and temporary regulations (T.D. 9790) that were published in the Federal Register on Friday, October 21, 2016 ( 81 FR 72858 ). The regulations relate to the determination of whether an interest in a corporation is treated as stock or indebtedness for all purposes of the Internal Revenue Code. DATES: These corrections are effective on January 23, 2017, and applicable October 21, 2016. FOR FURTHER INFORMATION CONTACT: Austin M. Diamond-Jones, (202) 317-5363, or Joshua G. Rabon, (202) 317-6938 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background The final and temporary regulations that are the subject of this correction are under sections 385 and 752 of the Internal Revenue Code. Need for Correction As published, the final regulations contain errors which may prove to be misleading and need to be clarified. Correction of Publication Accordingly, the final and temporary regulations (TD 9790) that are the subject of FR Doc. 2016-25105 are corrected as follows: 1. On page 72877, in the preamble, second column, the fourth sentence of the second full paragraph, “The Treasury Department and the IRS have considered this comment and determined that it would be appropriate to disregard subordination if the recharacterization o

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Related Documents

Other Federal Register documents from the same docket.

Full Document

Citation: 82 FR 8169