federal_register: 07-496

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
07-496 Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations Proposed Rule In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. These regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of those regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the temporary regulations and these proposed regulations. 2007-02-05 2007 2 https://www.federalregister.gov/documents/2007/02/05/07-496/certain-transfers-of-stock-or-securities-by-us-persons-to-foreign-corporations https://www.govinfo.gov/content/pkg/FR-2007-02-05/pdf/07-496.pdf Treasury Department; Internal Revenue Service 497,254 In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. These regulations are necessary to... 1545-BG09

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