[Federal Register Volume 82, Number 11 (Wednesday, January 18, 2017)]
[Proposed Rules]
[Page 5476]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-00636]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-135734-14]
RIN 1545-BM45


Rules Regarding Inversions and Related Transactions; Partial 
Withdrawal of Notice of Proposed Rulemaking

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Partial withdrawal of notice of proposed rulemaking.

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SUMMARY: This document withdraws portions of a notice of proposed 
rulemaking (REG-135734-14) published on April 8, 2016, in the Federal 
Register (81 FR 20588). The withdrawn portions relate to exceptions to 
general rules addressing certain transactions that are structured to 
avoid the purposes of section 7874 of the Internal Revenue Code (Code).

DATES: Portions of the proposed rules published on April 8, 2016, in 
the Federal Register (81 FR 20588) are withdrawn as of January 18, 
2017.

FOR FURTHER INFORMATION CONTACT: Joshua G. Rabon, (202) 317-6937.

SUPPLEMENTARY INFORMATION: 

Background

    On April 8, 2016, the Department of the Treasury (Treasury 
Department) and the IRS published in the Federal Register (81 FR 20588) 
proposed regulations (REG-135734-14), including in Sec. Sec.  1.7874-7 
and 1.7874-10, that address certain transactions that are structured to 
avoid the purposes of section 7874 of the Code. The regulations were 
proposed by cross-reference to temporary regulations (TD 9761) in the 
same issue of the Federal Register (81 FR 20858). In the Rules and 
Regulations section of this issue of the Federal Register, the Treasury 
Department and the IRS are amending certain aspects of the temporary 
regulations in Sec. Sec.  1.7874-7T and 1.7874-10T. Accordingly, the 
Treasury Department and the IRS are issuing a notice of proposed 
rulemaking in the Proposed Rules section of this issue of the Federal 
Register that proposes rules in Sec. Sec.  1.7874-7 and 1.7874-10 by 
cross-reference to the amended temporary regulations. This document 
withdraws the previously proposed regulations that are replaced by the 
notice of proposed rulemaking in the Proposed Rules section of this 
issue of the Federal Register.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Partial Withdrawal of a Notice of Proposed Rulemaking

    Accordingly, under the authority of 26 U.S.C. 7805, Sec. Sec.  
1.7874-7(c)(2) and (h) and 1.7874-10(d)(2) and (i) of the notice of 
proposed rulemaking (REG-135734-14) published in the Federal Register 
on April 8, 2016 (81 FR 20588) are withdrawn.

John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2017-00636 Filed 1-13-17; 4:15 pm]
 BILLING CODE 4830-01-P