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Application of Section 338 to Insurance Companies; Correction

---
identifier: "/us/fr/06-4272"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Application of Section 338 to Insurance Companies; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "06-4272"
section_name: "Application of Section 338 to Insurance Companies; Correction"
positive_law: false
currency: "2006-05-09"
last_updated: "2006-05-09"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "06-4272"
document_type: "rule"
publication_date: "2006-05-09"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-AY49"
fr_citation: "71 FR 26826"
fr_volume: 71
docket_ids:
  - "TD 9257"
effective_date: "2006-04-10"
fr_action: "Correcting amendment."
---

#  Effect of section 338 election on insurance company targets (temporary).

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document corrects final and temporary regulations (TD 9257) that were published in the *Federal Register* on Monday, April 10, 2006 (71 FR 17990) applying to a deemed sale or acquisition of an insurance company's assets pursuant to an election under section 338 of the Internal Revenue Code, to a sale or acquisition of an insurance trade or business subject to section 1060, and to the acquisition of insurance contracts through assumption reinsurance.

**DATES:**

This correction is effective April 10, 2006.

**FOR FURTHER INFORMATION CONTACT:**

Mark Weiss, (202) 622-7790 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final and temporary regulations (TD 9257) that are the subjects of this correction are under sections 197, 338, 381, and 1060 of the Internal Revenue Code.

**Need for Correction**

As published, TD 9257 contains an error that may prove to be misleading and is in need of clarification.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**26 CFR Part 1**

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read, in part, as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Section 1.338.11T is corrected by revising paragraph (d)(3)(ii)( *2* ) to read as follows:

§ 1.338-11T

(d) * * *

(3) * * *

(ii) * * *

( *2* ) B equals old target's undiscounted unpaid losses (determined under section 846(b)(1) as of the close of the acquisition date;

Guy R. Traynor,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).