IRS Corrects Gain Recognition Rules for Transfers to Foreign Trusts
REG-108522-00; 65 F.R. 58973
- Institutional AuthorsInternal Revenue Service
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Index Termsestates, foreign, transfers totrusts, foreign, transfers to
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2000-25361 (1 original page)
- Tax Analysts Electronic Citation2000 TNT 196-12
=============== SUMMARY ===============
The IRS has published corrections to the proposed regulations (REG-108522-00) governing the recognition of gain on transfers of appreciated property by U.S. persons to foreign trusts and estates. (For a summary of the regs, see Tax Notes, Aug. 7, 2000, p. 755; for the full text, see Doc 2000-20908 (5 original pages) or 2000 TNT 150- 6 ). The corrections are effective August 7, 2000.
This document appeared in TNT as 2000 TNT 192-8 and in the AccServ & Microfiche as Doc 2000-25280 (2 original pages).
=============== FULL TEXT ===============
[4830-01-U]
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-108522-00]
RIN 1545-AY25
[1] AGENCY: Internal Revenue Service (IRS), Treasury.
[2] ACTION: Correction to notice of proposed rulemaking.
[3] SUMMARY: This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on Monday, August 7, 2000 (65 FR 48198) relating to the recognition of gain on certain transfers to certain foreign trusts and estates.
[4] FOR FURTHER INFORMATION CONTACT: Karen A. Rennie Quarrie at (202) 622-3880 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
[5] The notice of proposed rulemaking that is the subject of this correction is under section 684 of the Internal Revenue Code.
Need for Correction
[6] As published, the notice of proposed rulemaking contains errors that may prove to be misleading and are in need of clarification.
Correction of Publication
[7] Accordingly, the publication of the notice of proposed rulemaking (REG-108522-00), that was the subject of FR Doc. 00-19896, is corrected as follows:
Section 1.684-3 [Corrected]
[8] On page 48202, column 1, section 1.684-3(f), the first line in Example 1, the language "Example 1. Transfer to owner trust. In" is corrected to read "Example 1. Transfer to grantor trust. In"
Cynthia E. Grigsby
Chief, Regulations Unit
Office of Special Counsel
(Modernization and Strategic
Planning)
- Institutional AuthorsInternal Revenue Service
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Index Termsestates, foreign, transfers totrusts, foreign, transfers to
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2000-25361 (1 original page)
- Tax Analysts Electronic Citation2000 TNT 196-12