# Agency Information Collection Activities; Comment Request on Comment Request on Notice 99-43, Nonrecognition Exchanges Under Section 897.
**AGENCY:**
Internal Revenue Service (IRS), Treasury.
**ACTION:**
Notice of information collection; request for comments.
**SUMMARY:**
In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice.
**DATES:**
Written comments should be received on or before May 4, 2026 to be assured of consideration.
**ADDRESSES:**
Direct all written comments to Andres Garcia, Internal Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 20224, or by email to *[email protected].* Include OMB Control Number 1545-1660 in the subject line of the message.
**FOR FURTHER INFORMATION CONTACT:**
Requests for additional information or copies of this collection should be directed to Marcus W. McCrary, 470-769-2001.
**SUPPLEMENTARY INFORMATION:**
The IRS, in accordance with the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3506(c)(2)(A)), provides the general public and Federal agencies with an opportunity to comment on proposed, revised, and continuing collections of information. This helps the IRS assess the impact and minimize the burden of its information collection requirements. Comments submitted in response to this notice will be summarized and/or included in the request for OMB approval. All comments will become a matter of public record, and viewable on relevant websites. For this reason, please do not include in your comments information of a confidential nature, such as sensitive personal information. Comments are invited on: (a) Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden of the collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology; and (e) estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.
*Title:* Notice 99-43, Nonrecognition Exchanges under Section 897.
*OMB Control Number:* 1545-1660.
*Regulation Project Number:* Notice 99-43.
*Abstract:* Notice 99-43 announced modification of the current rules under Temporary Regulation section 1.897-6T(a)(1) regarding transfers, exchanges and other dispositions of U.S. real property interests in nonrecognition transactions occurring after June 18, 1980. The notice provided that, contrary to section 1.897-6T(a)(1), a foreign taxpayer will not recognize a gain under Code 897(e) for an exchange described in Code section 368(a)(1)(E) or (F), provided the taxpayer receives substantially identical shares of the same domestic corporation with the same divided rights, voting power, liquidation preferences, and convertibility as the shares exchanged without any additional rights or features.
*Current Actions:* There is no change to the burden previously approved by OMB.
*Type of Review:* Extension of a currently approved collection.
*Affected Public:* Business or other for-profit organizations, individuals or households, and corporations.
*Estimated Number of Respondents:* 100.
*Estimated Time per Respondent:* 2 hours.
*Estimated Total Annual Burden Hours:* 200.
Dated: March 2, 2026.
Marcus W. McCrary,
Tax Analyst.