Sections 367(e)(1) and 367(e)(2)
provide for gain recognition on certain transfers to foreign
persons under sections 355 and 332. Section 6038B(a) requires U.S.
persons transferring property to foreign persons in exchanges
described in sections 332 and 355 to furnish information regarding
such transfers.
US Code:
26 USC 367(e)(2) Name of Law: Liquidation under section
332.
US Code: 26
USC 332 Name of Law: Complete liquidation of subsidiaries.
US Code:
26 USC 367(e)(1) Name of Law: Distributions describled in
section 355.
US Code: 26
USC 355 Name of Law: Distribution of stock and decurities of a
controlled corporation.
US Code: 26
USC 6038B Name of Law: Notice of certain transfers to foreign
persons.
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.