Federal Register / Vol. 83, No. 111 / Friday, June 8, 2018 / Rules and Regulations 26593 

(b) Aggregation of basis within 

consolidated group. With respect to 

distributed stock of a corporation, if the 

following two conditions are met, then 

section 732(f) shall apply only to the 

extent that the partnership’s adjusted 

basis in the distributed stock 

immediately before the distribution 

exceeds the aggregate basis of the 

distributed stock of the corporation in 

the hands of corporate partners that are 

members of the same consolidated 

group (as defined in § 1.1502–1(h)) 

immediately after the distribution: 

(1) Two or more of the corporate 

partners receive a distribution of stock 

in another corporation; and 

(2) The corporation, the stock of 

which was distributed by the 

partnership, is or becomes a member of 

the distributee partners’ consolidated 

group following the distribution. 

(c) Application of section 732(f) to 

Gain Elimination Transactions—(1) 

General rule. In the event of a Gain 

Elimination Transaction, section 732(f) 

shall apply as though the Corporate 

Partner acquired control (as defined in 

section 732(f)(5)) of the Distributed 

Corporation immediately before the 

Gain Elimination Transaction. 

(2) Definitions. The following 

definitions apply for purposes of this 

paragraph (c): 

(i) Corporate Partner. The term 

Corporate Partner means a person that 

is classified as a corporation for federal 

income tax purposes and that holds or 

acquires an interest in a partnership. 

(ii) Stock. The term Stock includes 

other equity interests, including 

options, warrants, and similar interests. 

(iii) Distributed Stock. The term 

Distributed Stock means Stock 

distributed by a partnership to a 

Corporate Partner, or Stock the basis of 

which is determined by reference to the 

basis of such Stock. Distributed Stock 

also includes Stock owned directly or 

indirectly by a Distributed Corporation 

if the basis of such Stock has been 

reduced pursuant to section 732(f). 

(iv) Distributed Corporation. The term 

Distributed Corporation means the 

issuer of Distributed Stock (or, in the 

case of an option, the issuer of the Stock 

into which the option is exercisable). 

(v) Gain Elimination Transaction. The 

term Gain Elimination Transaction 

means a transaction in which 

Distributed Stock is disposed of and less 

than all of the gain is recognized 

unless— 

(A) The transferor of the Distributed 

Stock receives in exchange Stock or a 

partnership interest that is exchanged 

basis property (as defined in section 

7701(a)(44)) with respect to the 

Distributed Stock; or 

(B) A transferee corporation holds the 

Distributed Stock as transferred basis 

property (as defined in section 

7701(a)(43)) with respect to the 

transferor corporation’s gain. A Gain 

Elimination Transaction includes 

(without limitation) a reorganization 

under section 368(a) in which the 

Corporate Partner and the Distributed 

Corporation combine, and a distribution 

of the Distributed Stock by the 

Corporate Partner to which section 

355(c)(1) or 361(c)(1) applies. 

(d) Tiered partnerships. The rules of 

this section shall apply to tiered 

partnerships in a manner that is 

consistent with the purposes of section 

732(f). 

(e) Applicability date. This section 

applies to transactions occurring on or 

after June 8, 2018. 

Kirsten Wielobob, 

Deputy Commissioner for Services and 

Enforcement. 

Approved: May 25, 2018. 

David J. Kautter, 

Assistant Secretary of the Treasury (Tax 

Policy). 

[FR Doc. 2018–12407 Filed 6–7–18; 8:45 am] 

BILLING CODE 4830–01–P 

DEPARTMENT OF HOMELAND 

SECURITY 

Coast Guard 

33 CFR Part 117 

[Docket No. USCG–2018–0516] 

Drawbridge Operation Regulation; 

Charles River, Boston, MA 

AGENCY: Coast Guard, DHS. 

ACTION: Notice of deviation from 

drawbridge regulation. 

SUMMARY: The Coast Guard has issued a 

temporary deviation from the operating 

schedule that governs the Massachusetts 

Department of Transportation (Craigie) 

Bridge across Charles River, mile 1.0, at 

Boston, Massachusetts. This deviation is 

necessary to facilitate the Boston Pops 

Fireworks Spectacular on July 4, 2018, 

and allows the bridge to remain in the 

closed position for two hours. 

DATES: This deviation is effective from 

11 p.m. on July 4, 2018 through 1 a.m. 

on July 5, 2018. 

ADDRESSES: The docket for this 

deviation, USCG–2018–0516 is available 

at http://www.regulations.gov. Type the 

docket number in the ‘‘SEARCH’’ box 

and click ‘‘SEARCH’’. Click on Open 

Docket Folder on the line associated 

with this deviation. 

FOR FURTHER INFORMATION CONTACT: If 

you have questions on this temporary 

deviation, call or email Jeffrey Stieb, 

Bridge Management Specialist, First 

District Bridge Branch, U.S. Coast 

Guard; telephone 617–223–8364, email 

Jeffrey.D.Stieb@uscg.mil. 

SUPPLEMENTARY INFORMATION: The 

Massachusetts Department of 

Transportation (Craigie) Bridge across 

Charles River, mile 1.0, at Boston, 

Massachusetts, has a vertical clearance 

of 12 feet at normal pool in the closed 

position. The existing drawbridge 

operating regulations are listed at 33 

CFR 117.591(e). 

The Massachusetts Department of 

Transportation requested a temporary 

deviation from the normal operating 

schedule. This temporary deviation will 

allow the bridge to remain closed from 

11 p.m. on July 4, 2018 through 1 a.m. 

on July 5, 2018 to allow pedestrian 

traffic to exit the Boston Pops Fireworks 

Spectacular. The waterway is used 

extensively by recreational traffic during 

the fireworks display. A State Police 

Unit will be on-scene to direct vessel 

traffic. Vessels that can pass under the 

bridge in the closed position may do so 

at any time. The bridge will be able to 

open for emergencies. There is no 

alternate route for vessels to pass. The 

Coast Guard will inform users of the 

waterway of the change in operating 

schedule through our Local and 

Broadcast Notices to Mariners so that 

vessel operators can arrange their 

transits to minimize any impact caused 

by the temporary deviation. 

In accordance with 33 CFR 117.35(e), 

the drawbridge must return to its regular 

operating schedule immediately at the 

end of the effective period of this 

temporary deviation. This deviation 

from the operating regulations is 

authorized under 33 CFR 117.35. 

Dated: June 4, 2018. 

C.J. Bisignano, 

Supervisory Bridge Management Specialist, 

First Coast Guard District. 

[FR Doc. 2018–12310 Filed 6–7–18; 8:45 am] 

BILLING CODE 9110–04–P 


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