Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization

---
identifier: "/us/fr/2010-416"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization"
title_number: 0
title_name: "Federal Register"
section_number: "2010-416"
section_name: "Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization"
positive_law: false
currency: "2010-01-13"
last_updated: "2010-01-13"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "2010-416"
document_type: "rule"
publication_date: "2010-01-13"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BI72"
fr_citation: "75 FR 1704"
fr_volume: 75
docket_ids:
  - "TD 9458"
effective_date: "2010-01-13"
fr_action: "Correcting amendment."
---


#  Intercompany transactions (temporary).

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**Summary:**

This document contains a correction to temporary regulations (TD 9458), which were published in the *Federal Register* on Friday, September 4, 2009, relating to modification to consolidated return regulation permitting an election to treat a liquidation of a target, followed by a recontribution to a new reorganization.

**DATES:**

The correction is effective January 13, 2010, and is applicable beginning September 4, 2009.

**FOR FURTHER INFORMATION CONTACT:**

Guy Traynor at (202) 622-3693 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The temporary regulation that is the subject to this correction is under section 1502 of the Internal Revenue Code.

**Need for Correction**

As published September 4, 2009 (74 FR 45757), temporary regulations (TD 9458), contains an error which 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 for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Paragraph (f)(5)(ii)(G) is added following paragraph (f)(5)(ii)(F)(3), to read as follows:

§ 1.1502-13T

(f) * * *

(5) * * *

(ii) * * *

(G) *Expiration date.* Paragraphs (f)(5)(ii)(B), (B)(1), (B)(2) and (F)(1), (2), and (3) of this section will expire on September 3, 2012.

Guy R. Traynor,

Federal Register Liaison, Publications & Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure & Administration).