Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners; Correction

Published date18 February 2020
Citation85 FR 8725
Record Number2020-02654
SectionRules and Regulations
CourtInternal Revenue Service,Treasury Department
Federal Register, Volume 85 Issue 32 (Tuesday, February 18, 2020)
[Federal Register Volume 85, Number 32 (Tuesday, February 18, 2020)]
                [Rules and Regulations]
                [Pages 8725-8726]
                From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
                [FR Doc No: 2020-02654]
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                DEPARTMENT OF THE TREASURY
                Internal Revenue Service
                26 CFR Part 1
                [TD 9891]
                RIN 1545-BM95
                Transfers of Certain Property by U.S. Persons to Partnerships
                With Related Foreign Partners; Correction
                AGENCY: Internal Revenue Service (IRS), Treasury.
                ACTION: Final regulations; correction.
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                SUMMARY: This document contains a correction to final regulations (T.D.
                9891) that were published in the Federal Register on Thursday, January
                23, 2020. Treasury Decision 9891 contains final regulations that
                provide guidance applicable to transfers of appreciated property by
                U.S. persons to partnerships with foreign partners related to the
                transferor.
                DATES:
                 Effective date: These regulations are effective February 18, 2020
                and applicable January 23, 2020.
                 Applicability dates: For dates of applicability, see Sec.
                1.721(c)-6.
                FOR FURTHER INFORMATION CONTACT: Chadwick Rowland, (202) 317-6937 (not
                a toll-free number).
                SUPPLEMENTARY INFORMATION:
                Background
                 The final regulations (TD 9891) that are the subject of this
                correction are issued under section 721 of the Internal Revenue Code.
                Need for Correction
                 As published, the final regulations (TD 9891), contains errors that
                may prove to be misleading and are in need of clarification.
                Correction to Publication
                 Accordingly, the final regulations (TD 9891), that are the subject
                of FR Doc. 2020-00383, in the issue of January 23, 2020 (85 FR 3833),
                are corrected as follows:
                0
                1. On page 3834, in the third column, in the second and third sentence
                of the second full paragraph, ``PRS1 wholly owns a domestic corporation
                (UST). In Year 1, UST forms a new partnership (PRS2); as part of the
                formation, UST contributes section 721(c) property (as defined in Sec.
                1.721(c)-1(b)(15)) in return for a 90 percent interest in PRS2's
                capital and profits, and a U.S. individual (unrelated to UST)
                contributes cash in return for the remaining interest in PRS2's capital
                and profits.'' is corrected to read ``PRS1 wholly owns a domestic
                corporation (UST) and holds 90 percent of the interests in a lower tier
                partnership's (PRS2) capital and profits. In Year 1, UST and PRS2 form
                a new partnership (PRS3); as part of the formation, UST contributes
                section 721(c) property (as defined in Sec. 1.721(c)-1(b)(15)) in
                return for a 90 percent interest in PRS3's capital and profits, and a
                U.S. individual (unrelated to UST) contributes cash in return for the
                remaining interest in PRS3's capital and profits''.
                0
                2. On page 3834, in the third column, the second line of the fourth
                partial paragraph, ``PRS2'' is corrected to read ``PRS3''.
                0
                3. On page 3835, in the first column, the second line from the bottom
                of the first full paragraph, ``consequence, PRS2'' is corrected to read
                ``consequence, PRS3''.
                [[Page 8726]]
                0
                4. On page 3835, in the third column, the third line from the bottom of
                the page, ``filed before March 17'' is corrected to read ``filed before
                July 17.''
                Martin V. Franks,
                Chief, Publications and Regulations Branch, Legal Processing Division,
                Associate Chief Counsel, (Procedure and Administration).
                [FR Doc. 2020-02654 Filed 2-14-20; 8:45 am]
                 BILLING CODE 4830-01-P
                

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