These temporary and proposed
regulations under IRC § 367(a) provide rules for taxpayers to avoid
recognizing gain under a gain recognition agreement (GRA) if a new
GRA and notice statement are filed. The regulations also provide a
rule under which a taxpayer may reduce the basis in certain stock
to meet one of the requirements for terminating a GRA. These
regulations also revise an existing rule to facilitate electronic
filing. The revision requires that information that a taxpayer
currently would write on the face of its Federal income tax return
shall instead be attached as a separate schedule to its
return
US Code:
44
USC 3507(d) Name of Law: Payments to be treated as payments of
withholding and FICA taxes
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.