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Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

---
identifier: "/us/fr/E6-16126"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Stock Transfer Rules: Carryover of Earnings and Taxes; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "E6-16126"
section_name: "Stock Transfer Rules: Carryover of Earnings and Taxes; Correction"
positive_law: false
currency: "2006-10-02"
last_updated: "2006-10-02"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "E6-16126"
document_type: "rule"
publication_date: "2006-10-02"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-AX65"
fr_citation: "71 FR 57888"
fr_volume: 71
docket_ids:
  - "TD 9273"
effective_date: "2006-08-08"
fr_action: "Correction to final regulations."
---

#  Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correction to final regulations.

**SUMMARY:**

This document contains a correction to final regulations (TD 9273) that were published in the *Federal Register* on Tuesday, August 8, 2006(71 FR 44887) addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is described in both section 367(b) and section 381 of the Internal Revenue Code (Code).

**DATES:**

This correction is effective August 8, 2006.

**FOR FURTHER INFORMATION CONTACT:**

Jeffrey L. Parry, (202) 622-3850 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The correction notice that is the subject of this document is under sections 367(b) and 381 of the Internal Revenue Code.

**Need for Correction**

As published, final regulations (TD 9273) contain an error that may prove to be misleading and is in need of clarification.

**Correction of Publication**

Accordingly, the publication of the final regulations (TD 9273), which was the subject of FR Doc. 06-6740, is corrected as follows:

On page 44889, column 3, in the preamble, under the paragraph heading *“B. Paradigm Based on Pooling Rather Than Look-Through”,* first paragraph of the column, line 11, the language “through-corporation included a” is corrected to read “through corporation included a”.

Guy R. Traynor,

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