Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction

---
identifier: "/us/fr/06-4533"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "06-4533"
section_name: "Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction"
positive_law: false
currency: "2006-05-16"
last_updated: "2006-05-16"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "06-4533"
document_type: "rule"
publication_date: "2006-05-16"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BA65"
fr_citation: "71 FR 28266"
fr_volume: 71
docket_ids:
  - "TD 9243"
effective_date: "2006-01-23"
fr_action: "Correcting amendment."
---


#  Effective dates and coordination rules.

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document contains a correction to final regulations (TD 9243), that was published in the *Federal Register* on Thursday, January 26, 2006 (71 FR 4276). This final regulation amends the income tax regulations under various provisions of the Internal Revenue Code to account for statutory mergers and consolidations.

**DATES:**

This correction is effective January 23, 2006.

**FOR FURTHER INFORMATION CONTACT:**

Christopher Trump (202) 622-3860 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final regulation (TD 9243) that is the subject of this correction is under section 367 of the Internal Revenue Code.

**Need for Correction**

As published, TD 9243 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 amendments:

**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**

§ 1.367(b)-6

*Par. 2.* Section 1.367(b)-6 is amended by removing the third sentence of  paragraph (a)(1) and adding the following sentence in its place to read as follows:

§ 1.367(b)-6

(a) * * *

(1) * * * Section 1.367(b)-4(b)(1)(ii) applies to all triangular reorganizations and reorganizations described in section 368(a)(1)(G) and (a)(2)(D) occurring on or after January 23, 2006, although taxpayers may apply § 1.367(b)-4(b)(1)(ii) to triangular B reorganizations occurring on or after February 23, 2000, that is not closed by the period of limitations if done consistently with respect to all such triangular B reorganizations.* * *

Guy R. Traynor,

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