federal_register: 2016-07295

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2016-07295 Partial Withdrawal of Proposed Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Partial Withdrawal of Proposed Guidance for Determining Stock Ownership Proposed Rule This document withdraws portions of a notice of proposed rulemaking published in the Federal Register on February 11, 2009. The withdrawn portions relate to the application of section 367(b) to transactions described in section 304(a)(1). This document also withdraws portions of a notice of proposed rulemaking published in the Federal Register on January 17, 2014. The withdrawn portions relate to the identification of certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation for purposes of section 7874. 2016-04-08 2016 4 https://www.federalregister.gov/documents/2016/04/08/2016-07295/partial-withdrawal-of-proposed-application-of-section-367-to-a-section-351-exchange-resulting-from-a https://www.govinfo.gov/content/pkg/FR-2016-04-08/pdf/2016-07295.pdf Treasury Department; Internal Revenue Service 497,254 This document withdraws portions of a notice of proposed rulemaking published in the Federal Register on February 11, 2009. The withdrawn portions relate to the application of section 367(b) to transactions described in section 304(a)(1). This document...  

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