Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 104909 

docket number found in brackets in the 

heading of this document into the 

‘‘Search’’ box and follow the prompts, 

and/or go to the Dockets Management 

Staff, 5630 Fishers Lane, Rm. 1061, 

Rockville, MD 20852. 

FOR FURTHER INFORMATION CONTACT: 

Katie Overbey, Human Foods Program, 

Food and Drug Administration, 5001 

Campus Dr., College Park, MD 20740, 

240–402–7536. 

SUPPLEMENTARY INFORMATION: Under 

section 409(b)(5) of the Federal Food, 

Drug, and Cosmetic Act (21 U.S.C. 

348(b)(5)), we are giving notice that we 

have filed a food additive petition (FAP 

5M4841), submitted by Monterey 

Mushrooms, LLC, 260 Westgate Dr., 

Watsonville, CA 95076. The petition 

proposes to amend the food additive 

regulations in § 172.382 (21 CFR 

172.382 Vitamin D2 mushroom powder) 

to provide for production of the additive 

by exposing sliced or diced edible 

cultivars of Agaricus bisporus to 

ultraviolet light. 

The petitioner has claimed that this 

action is categorically excluded from the 

requirement to prepare an 

environmental assessment or an 

environmental impact statement under 

21 CFR 25.32(k) because the substance 

is intended to remain in food through 

ingestion by consumers and is not 

intended to replace macronutrients in 

food. In addition, the petitioner has 

stated that, to their knowledge, no 

extraordinary circumstances exist. If 

FDA determines a categorical exclusion 

applies, neither an environmental 

assessment nor an environmental 

impact statement is required. If FDA 

determines a categorical exclusion does 

not apply, we will request an 

environmental assessment and make it 

available for public inspection. 

Dated: December 13, 2024. 

P. Ritu Nalubola, 

Associate Commissioner for Policy. 

[FR Doc. 2024–30362 Filed 12–23–24; 8:45 am] 

BILLING CODE 4164–01–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Part 1 

[REG–112129–23] 

RIN 1545–BQ84 

Corporate Alternative Minimum Tax 

Applicable After 2022; Technical 

Correction 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking; 

technical correction. 

SUMMARY: This document contains 

technical corrections to a notice of 

proposed rulemaking (REG–112129–23), 

which was published in the Federal 

Register on Friday, September 13, 2024. 

REG–112129–23 contains proposed 

regulations that relate to the application 

of the corporate alternative minimum 

tax, which is imposed on the adjusted 

financial statement income of certain 

corporations for applicable taxable years 

beginning after 2022. 

DATES: Written or electronic comments 

are still being accepted and must be 

received by Thursday, January 16, 2025. 

ADDRESSES: Commenters are strongly 

encouraged to submit public comments 

electronically via the Federal 

eRulemaking Portal at https://

www.regulations.gov (indicate IRS and 

REG–112129–23) by following the 

online instructions for submitting 

comments. Once submitted to the 

Federal eRulemaking Portal, comments 

cannot be edited or withdrawn. The 

Department of the Treasury (Treasury 

Department) and the IRS will publish 

for public availability any comments 

submitted to the IRS’s public docket. 

Send paper submissions to: 

CC:PA:01:PR (REG–112129–23), Room 

5203, Internal Revenue Service, P.O. 

Box 7604, Ben Franklin Station, 

Washington, DC 20044. 

FOR FURTHER INFORMATION CONTACT: 

Concerning general corrections 

(including corrections to proposed 

§§ 1.56A–1 and 1.59–2), Madeline 

Padner at (202) 317–7006, and 

concerning corrections to proposed 

§§ 1.56A–15 and 1.56A–16, C. Dylan 

Durham at (202) 317–7005, each of the 

Office of Associate Chief Counsel 

(Income Tax and Accounting); 

concerning corrections to proposed 

§§ 1.56A–5 and 1.56A–20, Elizabeth 

Zanet or Brian Barrett, each of the Office 

of Associate Chief Counsel 

(Passthroughs and Special Industries) at 

(202) 317–6850; concerning corrections 

to proposed §§ 1.56A–18, 1.56A–19, 

1.56A–21, 1.56A–23(e) and (f), and 

1.1502–56A, Jeremy Aron-Dine or 

William W. Burhop, each of the Office 

of Associate Chief Counsel (Corporate) 

at (202) 317–3181; concerning 

corrections to proposed § 1.56A–26, 

Michelle L. Ng at (202) 317–6939, and 

concerning § 1.59–4, John J. Lee at (202) 

317–6934, each of the Office of 

Associate Chief Counsel (International); 

and concerning submissions of 

comments or the public hearing, the 

Publications and Regulations Section, 

(202) 317–6901 (not toll-free numbers) 

or by email at publichearings@irs.gov 

(preferred). 

SUPPLEMENTARY INFORMATION: 

Background 

The notice of proposed rulemaking 

(REG–112129–23) that is the subject of 

these corrections is under sections 55, 

56A, 59, and 1502 of the Internal 

Revenue Code. 

Need for Correction 

As published, the notice of proposed 

rulemaking (REG–112129–23) contains 

errors that need to be corrected. 

The Treasury Department and the IRS 

intended that CAMT basis be used in 

amortizing or depreciating property not 

subject to the rules in proposed 

§ 1.56A–15 (AFSI adjustments for 

section 168 property) and proposed 

§ 1.56A–16 (AFSI adjustments for 

qualified wireless spectrum property). 

Therefore, the Treasury Department and 

IRS correct proposed § 1.56A–1(d)(4) to 

clarify that to the extent the CAMT basis 

of an asset is different than its AFS 

basis, and if income and expense (as 

well as gain or loss) is recognized for 

AFSI purposes under the section 56A 

regulations, then such income or 

expense (as well as gain or loss) 

reflected in FSI is redetermined for 

AFSI purposes by reference to the 

CAMT basis of the asset. 

The Treasury Department and the IRS 

intended that the simplified method for 

determining applicable corporation 

status take into account the adjustments 

provided to tax-exempt entities in 

section 56A(c)(12) and proposed 

§ 1.56A–14. Therefore, the Treasury 

Department and IRS correct proposed 

§ 1.59–2(g)(2) to take into account the 

adjustments provided to tax-exempt 

entities by proposed § 1.56A–14. 

The Treasury Department and the IRS 

intended proposed § 1.56A–19(g)(4)(iii) 

and (g)(5)(iii) to prevent a section 351 

transferee that is an applicable 

corporation from (i) causing a section 

351 exchange to be treated as a covered 

recognition transaction by issuing a de 

minimis amount of boot to a section 351 

transferor that is not an applicable 

corporation, and thereby (ii) 

determining the section 351 transferee’s 

CAMT basis in the assets received to be 

its AFS basis (that is, taking a fair value 

basis in the assets). Therefore, the 

Treasury Department and IRS correct 

proposed § 1.56A–19(g)(4)(iii) and 

(g)(5)(iii) to clarify that, if the amount of 

boot issued by the section 351 transferee 

to a section 351 transferor that is not an 

applicable corporation is less than ten 

percent of the fair market value of the 

assets transferred to the section 351 


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104910 Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 

transferee by that section 351 transferor, 

the section 351 transferee determines its 

CAMT basis in the transferred assets 

under section 362 (that is, the CAMT 

basis of the assets in the hands of the 

section 351 transferor), increased by the 

regular tax gain recognized by the 

section 351 transferor. Proposed 

§ 1.56A–19(g)(6)(iv) (Example 4) is 

revised to reflect the corrections to 

proposed § 1.56A–19(g)(5)(iii). 

This document also contains 

corrections for other errors contained in 

the notice of proposed rulemaking 

(REG–112129–23) that need to be 

corrected. 

Correction of Publication 

Accordingly, FR Doc. 2024–20089 

(REG–112129–23), appearing on page 

75062 in the Federal Register on Friday, 

September 13, 2024, is corrected as 

follows: 

1. On page 75063, in the third 

column, in the first partial paragraph, in 

the fifth line down from the top of the 

paragraph, the language ‘‘56(c)(3)(A)’’ is 

corrected to read ‘‘56A(c)(3)(A)’’. 

2. On page 75065, in the first column, 

in the second full paragraph, in the fifth 

line up from the bottom of the 

paragraph, the language ‘‘AFSI Tests’’ is 

corrected to read ‘‘AFSI tests’’. 

3. On page 75066, in the second 

column, in the first paragraph, in the 

third line down from the top of the 

paragraph, the language ‘‘2024–3 I.R.B.’’ 

is corrected to read ‘‘2024–3 I.R.B. 406’’. 

4. On page 75074, in the second 

column, in the first partial paragraph, in 

the tenth line up from the bottom of the 

paragraph, the language ‘‘388(g)’’ is 

corrected to read ‘‘338(g)’’. 

5. On page 75075, in the first column, 

in the thirteenth line up from the 

bottom of the page, the language ‘‘asset 

acquisition’’ is corrected to read ‘‘asset 

transaction’’. 

6. On page 75080, in the first column, 

the third line down from the top of the 

page is corrected to read ‘‘distributive 

share amount that is disallowed’’. 

7. On page 75086, in the third 

column, in the first full paragraph, the 

eighth line up from the bottom of the 

paragraph is corrected to read, ‘‘ending 

after December 31, 2019,’’. 

8. On page 75088, in the third 

column, in the first partial paragraph, 

the ninth line down from the top of the 

paragraph is corrected to read ‘‘in 

method of accounting for depreciation 

or a tax’’. 

9. On page 75088, in the third 

column, in the first full paragraph, in 

the ninth line up from the bottom of the 

paragraph, the language, ‘‘§ 1.56A– 

(d)(1)(iii)’’ is corrected to read, 

‘‘§ 1.56A–15(d)(1)(iii)’’. 

10. On page 75089, in the third 

column, in the first full paragraph, the 

language, ‘‘§ 1.56A–15(e)(7)’’ is 

corrected to read, ‘‘§ 1.56A–15(e)(8)’’. 

11. On page 75090, in the second 

column, in the first full paragraph, the 

second line up from the bottom of the 

paragraph is corrected to read ‘‘ending 

on or before December 31,’’. 

12. On page 75090, in the second 

column, in the second full paragraph, 

the second line up from the bottom of 

the paragraph is corrected to read 

‘‘ending on or before December 31,’’. 

13. On page 75091, in the second 

column, in the first full paragraph, the 

eighth line up from the bottom of the 

paragraph is corrected to read ‘‘taxable 

years ending on or before’’. 

14. On page 75101, in the first 

column, in the first partial paragraph: 

i. The ninth and eighth lines up from 

the bottom of the paragraph are 

corrected to read, ‘‘causing the deferred 

sale gain or loss to be accelerated into 

AFSI in’’. 

ii. The fifth line up from the bottom 

of the paragraph is corrected to read 

‘‘sum of (A) the deferred sale gain or 

loss that’’. 

15. On page 75101, in the third 

column, in the first partial paragraph, 

the last line of the paragraph is 

corrected to read ‘‘in which the 

distribution occurs unless the special 

rule in proposed § 1.56A–20(d)(1)(ii)(E) 

would apply to the timing of the 

inclusion.’’. 

16. On page 75103, in the third 

column, in the first partial paragraph, 

the seventh and sixth lines up from the 

bottom of the paragraph are corrected to 

read ‘‘which an acceleration or partial 

acceleration event described in 

§ 1.721(c)–4(b) or § 1.721(c)–5(d), 

respectively, occurred; and (D) the’’. 

17. On page 75105, in the second 

column, in the first partial and first full 

paragraphs, the language ‘‘Section 168 

Property’’, is corrected to read ‘‘section 

168 property’’, everywhere it appears. 

18. On page 75113, in the first 

column, the heading ‘‘3. Corporation in 

Existence for Less Than Three Taxable 

Years’’ is corrected to read ‘‘3. 

Corporation in Existence for Less Than 

Three Taxable Years and Short Taxable 

Years’’. 

19. On page 75120, in the first 

column, in the second partial paragraph, 

in the twelfth line up from the bottom 

of the paragraph, the language ‘‘section 

904’’ is corrected to read ‘‘section 901’’. 

20. On page 75120, in the third 

column, the heading ‘‘XXX. Proposed 

§§ 1.1502–2, 1.1502–3, 1.1502–53, and 

1.1502–55: Computation of Tax Liability 

of a Tax Consolidated Group and 

Computation of Alternative Minimum 

Tax of Consolidated Groups’’ is 

corrected to read ‘‘XXX. Proposed 

§§ 1.1502–2, 1.1502–3, 1.1502–53, and 

1.1502–55: Computation of Tax Liability 

of a Tax Consolidated Group and 

Computation of Minimum Tax Credits 

of Consolidated Groups’’. 

21. On page 75124, in the third 

column, in the second full paragraph, in 

the ninth line down from the top of the 

paragraph, the language ‘‘beginning 

after’’ is corrected to read ‘‘ending 

after’’. 

22. On page 75125, in the second 

column, in the first full paragraph, in 

the eighteenth line down from the top 

of the paragraph, the language 

‘‘beginning after’’ is corrected to read 

‘‘ending after’’. 

23. On page 75125, in the second 

column, in the first full paragraph, in 

the twenty-third line down from the top 

of the paragraph, following the word 

‘‘holds’’, the word ‘‘the’’ is removed. 

24. On page 75125, in the third 

column, in the first paragraph, in the 

tenth line down from the top of the 

paragraph, the language ‘‘beginning after 

December 31, 2019.’’ is corrected to read 

‘‘ending after December 31, 2019.’’. 

25. On page 75127, in the first 

column, in the last partial paragraph, in 

the fourth line up from the bottom of the 

page, following the word ‘‘applicable’’, 

the language ‘‘and also apply all of the 

rules in proposed §§ 1.56A–4 and 

1.56A–6 that apply to transfers (as 

defined in proposed § 1.56A–4(b)(3)) to 

any transfers occurring in such taxable 

years’’ is added. 

26. On page 75127, in the first 

column, in the last partial paragraph, 

the second line up from the bottom of 

the page is corrected to read ‘‘and 

1.56A–6 that apply to transfers,’’ and 

the last line of the page is removed. 

27. On page 75127, in the second 

column, in the first partial paragraph, in 

the fifth line up from the bottom of the 

paragraph, following the language 

‘‘September 13, 2024,’’ the language 

‘‘during a taxable year of the taxpayer 

and each subsequent taxable year until 

the final regulations are applicable to 

such transfers,’’ is added. 

28. On page 75127, in the second 

column, in the first full paragraph, 

following the word ‘‘applicable’’ in the 

sixteenth line up from the bottom of the 

paragraph, the language ‘‘and also apply 

all of the rules described in proposed 

§§ 1.56A–4 and 1.56A–6 that apply to 

any transfers occurring in such taxable 

years’’ is added. 

29. On page 75130, in the second 

column, under the authority citation for 

Part 1, in the last paragraph in the 

column, in the entry for §§ 1.1502–53 

and 1.1502–56A, the language 


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‘‘56A(C)(2)(B)’’ is removed, and the 

language ‘‘56A(c)(2)(B)’’ is added in its 

place. 

§ 1.56A–0 [Corrected] 

30. On page 75135, in the third 

column, the entry for § 1.56A– 

20(c)(2)(iv) is corrected to read as 

follows: 

* * * * * 

§ 1.56A–20 AFSI adjustments to apply 

certain subchapter K principles. 

* * * * * 

(c) * * * 

(2) * * * 

(iv) Inclusion of deferred sale gain 

upon an acceleration or partial 

acceleration event described in 

§ 1.721(c)–4(b) or § 1.721(c)–5(d). 

* * * * * 

31. On page 75136, in the second 

column, the entries for § 1.56A–21(c)(6) 

introductory text and (c)(6)(i) through 

(iv) are redesignated as entries for 

§ 1.56A–21(c)(7) introductory text and 

(c)(7)(i) through (iv), and a new entry for 

§ 1.56A–21(c)(6) is added to read as 

follows: 

* * * * * 

§ 1.56A–21 AFSI adjustments for 

troubled companies. 

* * * * * 

(c) * * * 

(6) Exclusion from AFSI. 

(7) Examples. 

(i) Example 1: Bankruptcy emergence 

in a covered nonrecognition transaction. 

(ii) Example 2: Bankruptcy emergence 

in a covered recognition transaction. 

(iii) Example 3: Attribute reduction. 

(iv) Example 4: Excluded income from 

the discharge of indebtedness of 

insolvent taxpayer. 

* * * * * 

§ 1.56A–1 [Corrected] 

32. On page 75140, in the second 

column, in paragraph (c)(4)(ii), the last 

line of the paragraph is corrected to read 

‘‘18(c)(3) and (4) and 1.56A–4(c)(4) and 

(d)(4)).’’ 

33. On page 75142, in the first 

column, in paragraph (d)(4): 

i. The paragraph heading is corrected 

to read, ‘‘(4) Redetermination of FSI.’’. 

ii. The third line down from the top 

of the paragraph is corrected to read, 

‘‘the section 56A regulations, if income, 

expense, gain or’’. 

iii. The seventh line up from the 

bottom of the paragraph is corrected to 

read, ‘‘different from its AFS basis, and 

if such income, expense,’’. 

iv. The fourth line up from the bottom 

of the paragraph is corrected to read, 

‘‘regulations, then such income, 

expense, gain or loss’’. 

§ 1.56A–5 [Corrected] 

34. On page 75154, in the third 

column, in paragraph (k)(4)(i), in the 

sixth and fourth lines up from the 

bottom of the paragraph, the language 

‘‘AFS $50’’ is corrected to read ‘‘AFS 

$50x’’. 

35. On page 75155, in the first 

column, in paragraph (k)(5)(i): 

i. In the fifth line down from the top 

of the page, the language ‘‘AFS $75’’ is 

corrected to read ‘‘AFS $75x’’. 

ii. In the sixth and eighth lines down 

from the top of the page, the language 

‘‘AFS $50’’ is corrected to read ‘‘AFS 

$50x’’. 

36. On page 75155, in the third 

column, in paragraph (k)(7), the eighth 

line up from the bottom of the 

paragraph is corrected to read, 

‘‘property owned by PRS1. As a result 

of’’. 

§ 1.56A–15 [Corrected] 

37. On page 75163, in the second 

column: 

i. In paragraph (b)(11)(i), in the third 

line up from the bottom of the 

paragraph, the language ‘‘beginning 

after’’ is corrected to read ‘‘ending 

after’’. 

ii. In paragraph (b)(11)(ii), the fifth 

line up from the bottom of the 

paragraph, the language ‘‘beginning after 

December 31, 2019,’’ is corrected to read 

‘‘ending after December 31, 2019,’’. 

38. On page 75165, in the first 

column, in paragraph (d)(4), the seventh 

line up from the bottom of the column 

is corrected to read, ‘‘taxable year were 

a full 12-month taxable’’. 

39. On page 75168, in the first 

column, in paragraph (d)(5)(v)(C), in the 

thirteenth line up from the bottom of the 

paragraph, the number ‘‘481’’ is 

corrected to read, ‘‘481(a)’’. 

40. On page 75168, in the second 

column, in paragraph (d)(5)(v)(D): 

i. The thirteenth line down from the 

top of the page is corrected to read, 

‘‘taxable years ending after’’. 

ii. The twentieth and twenty-first 

lines down from the top of the page are 

corrected to read ‘‘respect to taxable 

years ending after December 31, 2019, 

and before the’’. 

iii. The ninth and tenth lines up from 

the bottom of the paragraph are 

corrected to read, ‘‘to taxable years 

ending after December 31, 2019, and 

before the tax’’. 

41. On page 75168, in the third 

column, in paragraph (d)(5)(vi)(B), in 

the thirteenth line up from the bottom 

of the paragraph, the word ‘‘be’’ is 

removed. 

42. On page 75169, in the first 

column, in paragraph (d)(5)(vi)(C): 

i. The eighth line down from the top 

of the page is corrected to read, ‘‘ending 

after December 31, 2019,’’. 

ii. The sixteenth line down from the 

top of the page is corrected to read, 

‘‘ending after December 31, 2019,’’. 

iii. The eighth line up from the 

bottom of the paragraph is corrected to 

read ‘‘years ending after December 31,’’. 

43. On page 75170, in the first 

column, in paragraph (d)(5)(ix)(A), the 

sixth line up from the bottom of the 

paragraph is corrected to read, ‘‘PRS1. 

As a result of the basis adjustment,’’. 

44. On page 75170, in the second 

column, in paragraph (d)(5)(x)(A), the 

fourth line up from the bottom of the 

paragraph is corrected to read, ‘‘As a 

result of the basis adjustment, X is’’. 

45. On page 75173, in the second 

column, in paragraph (e)(8)(iii)(B), the 

third line up from the bottom of 

paragraph is corrected to read, 

‘‘following the Exchange/40 years) of’’. 

46. On page 75174, in the first 

column, in paragraph (e)(8)(iv)(A): 

i. In the fifth line up from the bottom 

of the paragraph, the number ‘‘$50’’ is 

corrected to read ‘‘$50x’’. 

ii. The fourth line up from the bottom 

of the paragraph is corrected to read 

‘‘sale of Property A ($900x’’. 

iii. In the third line up from the 

bottom of the paragraph the number 

‘‘$850’’ is corrected to read ‘‘$850x’’. 

iv. The last line of the paragraph is 

corrected to read, ‘‘expense)).’’. 

47. On page 75176, in the first 

column, in paragraph (e)(8)(ix)(B), in the 

sixth line up from the bottom of the 

page, the word ‘‘to’’ is corrected to read 

‘‘into’’. 

48. On page 75176, in the third 

column, in paragraph (e)(8)(xi)(A), the 

seventh line up from the bottom of the 

paragraph is corrected to read ‘‘owned 

by PRS1. As a result of the basis’’. 

49. On page 75177, in the first 

column, in paragraph (e)(8)(xi)(C), the 

second line up from the bottom of the 

paragraph is corrected to read ‘‘§ 1.56A– 

5(e)(1)(iv) and (e)(4)(ii)(A),’’. 

§ 1.56A–16 [Corrected] 

50. On page 75177, in the second 

column, in paragraph (b)(8)(i), the third 

line up from the bottom of the 

paragraph is corrected to read, ‘‘to 

taxable years ending after’’. 

51. On page 75177, in the second 

column, in paragraph (b)(8)(ii), the sixth 

line up from the bottom of the 

paragraph is corrected to read, ‘‘with 

respect to taxable years ending’’. 

52. On page 75179, in the first 

column, in paragraph (e)(2)(ii)(D), the 

tenth line up from the bottom of the 

page is corrected to read ‘‘adjustments 

described in paragraphs’’. 


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104912 Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 

§ 1.56A–17 [Corrected] 

53. On page 75180, in the third 

column, in the first full paragraph, in 

paragraph (c)(2)(i)(A), the second line 

up from the bottom of the paragraph is 

corrected to read ‘‘ending on or before 

December 31,’’. 

54. On page 75180, in the third 

column, in paragraph (c)(2)(ii)(A), in the 

second line up from the bottom of the 

paragraph, the language ‘‘beginning on 

or before’’ is corrected to read ‘‘ending 

on or before’’. 

55. On page 75180, in the third 

column, the paragraph heading for 

paragraph (c)(3)(ii)(A) is corrected to 

read, ‘‘(ii) Omissions—(A) Increase to 

AFSI.’’. 

56. On page 75181, in the third 

column, in paragraph (d)(1)(i): 

i. In the twenty-fourth line up from 

the bottom of the paragraph, the 

language ‘‘beginning after December’’ is 

corrected to read ‘‘ending after 

December’’. 

ii. In the sixth line up from the bottom 

of the paragraph, the language ‘‘taxable 

years beginning’’ is corrected to read 

‘‘taxable years ending’’. 

57. On page 75182, in the third 

column, paragraph (g) is corrected to 

read as follows: 

* * * * * 

(g) Applicability date—(1) In general. 

Except as provided in paragraph (g)(2) 

of this section, this section applies to 

taxable years ending after September 13, 

2024. 

(2) Rule for changes in accounting 

principle and restatements of a prior 

year’s AFS. In the case of rules 

contained in paragraphs (c) and (d) of 

this section, those rules are applicable 

to changes in accounting principle 

implemented in, and restated AFS 

issued in, taxable years ending after 

September 13, 2024. 

§ 1.56A–18 [Corrected] 

58. On page 75182, in the third 

column, in paragraph (a)(2)(i), in the 

third line down from the top of the 

paragraph, the language ‘‘shareholders 

of other’’ is removed. 

59. On page 75183, in the third 

column, in paragraph (b)(9)(i), in the 

last line of the column, the word 

‘‘respectively,’’ is removed. 

60. On page 75184, in the first 

column, in paragraph (b)(12)(i)(A), in 

the second line of the paragraph, the 

language ‘‘the corporation’’ is corrected 

to read ‘‘that party or property’’. 

61. On page 75184, in the third 

column, paragraph (b)(19)(xv) is 

corrected to read ‘‘(xv) A transferor 

corporation; and’’. 

62. On page 75186, in the second 

column, the last sentence in paragraph 

(c)(6) is removed. 

63. On page 75187, in the second 

column, in paragraph (c)(8)(vi)(C), in the 

second line up from the bottom of the 

page, the word ‘‘transaction’’ is 

corrected to read ‘‘exchange’’. 

64. On page 75187, in the third 

column, in paragraph (c)(8)(vi)(E), in the 

third line up from the bottom of the 

paragraph, the word ‘‘transaction’’ is 

corrected to read ‘‘exchange’’. 

65. On page 75188, in the third 

column, in paragraph (d)(4)(iv), the 

second line of the paragraph is corrected 

to read ‘‘recipient’s CAMT basis in the 

other property’’. 

66. On page 75189, in the first 

column, in paragraph (d)(5)(i)(A), the 

first partial paragraph, the fourth line 

down from the top of the page is 

corrected to read ‘‘issued stock with a 

fair market value of $25x to X (that is, 

a distribution’’. 

67. On page 75189, in the third 

column, in paragraph (d)(5)(iv)(B), the 

last two lines up from the bottom of the 

paragraph are corrected to read ‘‘section 

312 by the amount of AFSI, or $12.5x.’’. 

68. On page 75190, in the first 

column, in paragraph (e)(2)(ii), the last 

three lines of the paragraph are 

corrected to read ‘‘equal to the target 

corporation’s AFS basis in that property 

that would obtain if the transaction 

were treated as an asset sale for AFS 

purposes.’’. 

69. On page 75190, in the third 

column, in paragraph (e)(6), the last two 

lines of the paragraph are corrected to 

read ‘‘AFS basis in that property that 

would obtain if the transaction were 

treated as an asset sale for AFS 

purposes.’’. 

70. On page 75190, in the third 

column, in paragraph (e)(7)(i), in the 

tenth line down from the top of the 

paragraph, the language ‘‘a regular tax’’ 

is corrected to read ‘‘an AFS’’. 

71. On page 75190, in the third 

column, in paragraph (e)(7)(ii), the last 

line of the page is corrected to read 

‘‘Distributing applies section 336(e) to 

the’’. 

72. On page 75191, in the first 

column, in paragraph (e)(7)(ii), the first 

partial paragraph, in the fourth line up 

from the bottom of the paragraph, the 

number ‘‘$66x’’ is corrected to read 

‘‘$60x’’. 

73. On page 75191, in the first 

column, in the first partial paragraph, 

paragraph (e)(7)(ii), in the last line of the 

paragraph, the language ‘‘regular tax’’ is 

corrected to read ‘‘AFS’’. 

74. On page 75193, in the first 

column, in paragraph (g)(4), the last two 

lines of the paragraph are corrected to 

read ‘‘corporation’s AFS basis in that 

property that would obtain if the 

transaction were treated as an asset sale 

for AFS purposes.’’. 

75. On page 75193, in the first 

column, in paragraph (g)(6)(i)(A), in the 

second line up from the bottom of the 

paragraph, the language ‘‘and a value of 

$30x’’ is removed. 

76. On page 75193, in the second 

column, in the first partial paragraph, 

paragraph (g)(6)(ii)(B), in the last line of 

the paragraph, the language ‘‘regular 

tax’’ is corrected to read ‘‘AFS’’ 

77. On page 75193, in the second 

column, in paragraph (g)(6)(iii)(A), in 

the fourteenth line up from the bottom 

of the paragraph, the language ‘‘regular 

tax’’ is corrected to read ‘‘AFS’’. 

78. On page 75193, in the second 

column, in paragraph (g)(6)(iii)(B), the 

last two lines of the paragraph are 

corrected to read ‘‘assets is equal to new 

Target’s AFS basis in those assets, or 

$100x.’’. 

§ 1.56A–19 [Corrected] 

79. On page 75194, in the third 

column, in paragraph (b)(4)(i), the 

eighth line up from the bottom of the 

paragraph is corrected to read 

‘‘paragraphs (b)(1) and (3) of this’’. 

80. On page 75195, in the second 

column, in paragraph (b)(7)(ii): 

i. The seventh line down from the top 

of the paragraph is corrected to read ‘‘of 

Acquiror nonvoting stock.’’ and the 

eighth line down from the top of the 

paragraph is removed. 

ii. The thirteenth through tenth lines 

up from the bottom of the paragraph are 

corrected to read ‘‘determines its AFSI 

by redetermining any FSI reflected in its 

AFS resulting from the transaction by 

reference to its CAMT basis in the 

Target stock. As a result, X’’. 

81. On page 75196, in the third 

column, in the first full paragraph, 

paragraph (c)(8)(i)(A), in the fourth line 

up from the bottom of the paragraph, the 

language ‘‘and a value of $30x’’ is 

removed. 

82. On page 75198, in the second 

column, in paragraph (d)(6)(i)(A), the 

seventeenth line up from the bottom of 

the paragraph is corrected to read 

‘‘transactions that qualify for 

nonrecognition treatment under 

section’’. 

83. On page 75198, in the second 

column, in paragraph (d)(6)(i)(B), the 

sixth line up from the bottom of the 

page is corrected to read, ‘‘Contribution, 

or $0x. Additionally, under paragraph 

(d)(1)(i)(C) of this section, Distributing 

adjusts its CAMT earnings resulting 

from the Controlled Split-Off by 

applying section 312. Under 

paragraph’’. 


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Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 104913 

84. On page 75198, in the third 

column, in paragraph (d)(6)(ii)(A), the 

seventh line up from the bottom of the 

paragraph is corrected to read ‘‘$200x, 

and additionally Controlled transfers 

$10x cash to’’. 

85. On page 75198, in the third 

column, in paragraph (d)(6)(iii)(A), the 

seventh through third lines up from the 

bottom of the page are corrected to read 

‘‘$210x, and additionally Distributing 

receives $20x of cash. Distributing 

distributes only $15x of the cash 

received from Controlled to its 

shareholders.’’. 

86. On page 75199, in the first 

column, in paragraph (d)(6)(iii)(B): 

i. In the second through seventh lines 

down from the top of the paragraph, the 

language, ‘‘Distributing distributed 

Controlled securities with a fair market 

value of more than the adjusted basis of 

the property transferred to Controlled, 

resulting in gain to Distributing under 

section 361(b)(3),’’ is removed and the 

language ‘‘Distributing did not purge all 

of the boot received from Controlled in 

the Contribution,’’ is added in its place. 

ii. The ninth line down from the top 

of the paragraph is corrected to read ‘‘is 

a covered recognition transaction. See 

paragraph (d)(6)(iii)(D) (Example 3) of 

this section.’’. 

iii. The last line of the paragraph is 

corrected to read ‘‘$190x. Under 

paragraph (d)(5)(i)(A) of this section, the 

Contribution is a covered recognition 

transaction to Controlled. Under 

paragraph (d)(5)(ii)(B) of this section 

Controlled’s CAMT basis in the property 

received from Distributing is its AFS 

basis, or $210x.’’. 

87. On page 75199, in the first 

column, in paragraph (d)(6)(iii)(C), the 

sixth line down from the top of the 

paragraph is corrected to read ‘‘of this 

section (Example 1). Under paragraph 

(d)(1)(i)(C) of this section, Distributing 

adjusts its CAMT earnings resulting 

from the Controlled Split-Off by 

applying section 312. Under’’. 

88. On page 75199, in the second 

column, in paragraph (e)(2)(ii), the 

fourth and third lines up from the 

bottom of the paragraph are corrected to 

read ‘‘or security holder. See § 1.56A– 

18(d) for rules’’. 

89. On page 75201, in the third 

column, in paragraph (g)(4)(ii), in the 

third line up from the bottom of the 

paragraph, the language ‘‘CAMT gain’’ is 

corrected to read ‘‘AFSI’’. 

90. On page 75201, in the third 

column, the introductory text of 

paragraph (g)(4)(iii) is corrected to read 

as follows: 

* * * * * 

(g) * * * 

(4) * * * 

(iii) Special CAMT basis limitation 

rule. If the requirements of paragraphs 

(g)(4)(iii)(A) through (C) of this section 

are satisfied, the section 351 transferee 

determines its CAMT basis under 

paragraph (g)(4)(ii) of this section in the 

property received from a section 351 

transferor by applying section 362 using 

the CAMT basis (in lieu of AFS basis) 

of that property, increased by the 

amount of gain recognized to the section 

351 transferor on the transfer for regular 

tax purposes. 

* * * * * 

91. On page 75202, in the first 

column, the introductory text of 

paragraph (g)(5)(iii) is corrected to read 

as follows: 

* * * * * 

(g) * * * 

(5) * * * 

(iii) Special CAMT basis limitation 

rule. If the requirements of paragraphs 

(g)(5)(iii)(A) through (C) of this section 

are satisfied, the section 351 transferee 

determines its CAMT basis under 

paragraph (g)(5)(ii) of this section in the 

property received from a section 351 

transferor by applying section 362 using 

the CAMT basis (in lieu of AFS basis) 

of that property, increased by the 

amount of gain recognized to the section 

351 transferor on the transfer for regular 

tax purposes. 

* * * * * 

92. On page 75202, in the second 

column, in paragraph (g)(6), the last line 

of the introductory text is corrected to 

read ‘‘of a tax consolidated group. 

Additionally, X is a section 351 

transferor, and Y is a section 351 

transferee.’’. 

93. On page 75202, in the second 

column, in paragraph (g)(6)(i): 

i. The language ‘‘Acquiror’’ is 

removed, and the language ‘‘X’’ is added 

in its place, everywhere it appears. 

ii. The language ‘‘Target’’ is removed, 

and the language ‘‘Y’’ is added in its 

place everywhere it appears. 

94. On page 75202, in the second 

column, in paragraph (g)(6)(ii)(A): 

i. In the third line up from the bottom 

of the paragraph, the language 

‘‘Acquiror’’ is corrected to read ‘‘X’’. 

ii. In the second line up from the 

bottom of the paragraph, the language 

‘‘Target’’ is corrected to read ‘‘Y’’. 

95. On page 75202, in the second and 

third columns, paragraph (g)(6)(ii)(B) is 

corrected to read as follows: 

* * * * * 

(g) * * * 

(6) * * * 

(ii) * * * 

(B) Analysis. The Exchange is a 

covered recognition transaction to each 

of X and Y. See paragraph (g)(1)(ii) of 

this section. Under paragraph (g)(3)(i) of 

this section, X redetermines its AFSI by 

computing any gain or loss using its 

CAMT basis in the assets transferred to 

Y, or $50x ($90x–$40x). Under 

paragraph (g)(3)(ii) of this section, X’s 

CAMT basis in the Y stock received is 

its AFS basis, or $80x. Under paragraph 

(g)(3)(iii) of this section, X adjusts its 

CAMT retained earnings by the amount 

of AFSI resulting from the Exchange, or 

$50x. Because Y transfers only cash and 

stock to X in the Exchange, under 

paragraph (g)(5)(i) of this section, Y 

disregards any FSI resulting from the 

Exchange and instead determines AFSI 

using CAMT basis. Under paragraph 

(g)(5)(ii) of this section, Y determines its 

CAMT basis using its AFS basis in the 

property. Paragraph (g)(5)(iii) of this 

section does not apply. Under paragraph 

(g)(5)(iv) of this section, Y adjusts its 

CAMT retained earnings by the amount 

of AFSI recognized on the Exchange. 

* * * * * 

96. On page 75202, in the third 

column, in paragraph (g)(6)(iii)(A): 

i. In the fourth line up from the 

bottom of the paragraph, the language 

‘‘X’’ is corrected to read ‘‘Z’’. 

ii. The language ‘‘Target’’ is corrected 

to read ‘‘Y’’, everywhere it appears, 

97. On page 75202, in the third 

column, in paragraph (g)(6)(iii)(B): 

i. The language ‘‘X’’ is corrected to 

read ‘‘Z’’ everywhere it appears. 

ii. The language ‘‘Acquiror’’ is 

corrected to read ‘‘X’’ everywhere it 

appears. 

iii. The language ‘‘Target’’ is corrected 

to read ‘‘Y’’ everywhere it appears. 

98. On page 75202, in the third 

column, in paragraph (g)(6)(iv)(A): 

i. In the fourth line up from the 

bottom of the paragraph, the language 

‘‘Acquiror’’ is corrected to read ‘‘X’’. 

ii. In the second line up from the 

bottom of the paragraph, the language 

‘‘Target’’ is corrected to read ‘‘Y’’. 

99. On page 75202, in the third 

column, in paragraph (g)(6)(iv)(B): 

i. The second line down from the top 

of the paragraph is corrected to read 

‘‘transferred by Y to X in the’’. 

ii. In the fifth line down from the top 

of the paragraph, the language ‘‘Target’’ 

is corrected to read ‘‘Y’’. 

iii. In the sixth line down from the top 

of the paragraph, the language 

‘‘Acquiror’’ is corrected to read ‘‘X’’. 

iv. The last five lines of the page are 

corrected to read ‘‘Y’s CAMT basis in 

the assets received from X is determined 

under section 362, using CAMT basis in 

lieu of AFS basis, increased by any gain 

recognized by X for regular tax 

purposes, or $45x ($40x + $5x).’’. 


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104914 Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 

100. On page 75203, in the first 

column, the first two lines of the page 

are removed. 

§ 1.56A–20 [Corrected] 

101. On page 75203, in the first 

column, in paragraph (a)(1), in the 

twelfth and thirteenth lines down from 

the top of the paragraph, the language 

‘‘sets forth the scope of this section and’’ 

is removed. 

102. On page 75203, in the third 

column, in paragraph (c)(2)(i)(E), the 

eighth line down from the top of the 

paragraph is corrected to read ‘‘year and 

thus subject to depreciation or 

amortization in’’. 

103. On page 75203, in the third 

column, the paragraph heading of 

paragraph (c)(2)(ii) is corrected to read 

‘‘(ii) Inclusion of deferred sale gain or 

loss upon a decrease in contributor’s 

distributive share percentage—(A) In 

general.’’. 

104. On page 75204, in the first 

column, in paragraph (c)(2)(ii)(A), the 

fifth line up from the bottom of the 

paragraph is corrected to read ‘‘(c)(2)(ii) 

as a result of a decrease in the’’. 

105. On page 75204, in the second 

column, the paragraph heading of 

paragraph (c)(2)(iv) is corrected to read 

‘‘(iv) Inclusion of deferred sale gain 

upon an acceleration or partial 

acceleration event described in 

§ 1.721(c)–4(b) or § 1.721(c)–5(d).’’. 

106. On page 75204, in the third 

column, in paragraph (c)(3)(ii)(B), the 

second and third lines of the paragraph 

are corrected to read ‘‘causing the 

deferred sale gain or loss to be 

accelerated into AFSI in’’. 

107. On page 75205, in the second 

column, in paragraph (d)(1)(ii)(C), in the 

fourth line down from the top of the 

page, the word ‘‘sale’’ is corrected to 

read ‘‘distribution’’. 

108. On page 75205, in the second 

column, in paragraph (d)(1)(ii)(D), in the 

second to last line of the paragraph, the 

word ‘‘sale’’ is corrected to read 

‘‘distribution’’. 

109. On page 75205, in the second 

column, in paragraph (d)(1)(ii)(E), in the 

fourth line up from the bottom of the 

paragraph, the word ‘‘sale’’ is corrected 

to read ‘‘distribution’’. 

110. On page 75206, in the third 

column, paragraph (g)(2)(i)(C) is 

corrected to read, ‘‘(C) The date on 

which an acceleration event or partial 

acceleration event described in 

§ 1.721(c)–4(b) or § 1.721(c)–5(d), 

respectively, occurred; and’’. 

111. On page 75207, in the third 

column, in paragraph (h)(3)(ii)(B), in the 

second line down from the top of the 

page, the number ‘‘$437.5’’ is corrected 

to read ‘‘$437.5x’’. 

112. On page 75207, in the third 

column, in paragraph (h)(5)(ii), in the 

second and tenth lines up from the 

bottom of the paragraph, the number 

‘‘$5,000’’ is corrected to read ‘‘$5,000x’’. 

§ 1.56A–21 [Corrected] 

113. On page 75209, in the third 

column, in paragraph (b)(3)(iii): 

i. The last line of the introductory text 

is corrected to read ‘‘indebtedness of the 

CAMT entity that results from—‘‘. 

ii. Paragraph (b)(3)(iii)(A) is removed. 

iii. Paragraph (b)(3)(iii)(B) is 

redesignated as new paragraph 

(b)(3)(iii)(A) and the first line of the 

newly redesignated paragraph is 

corrected to read ‘‘(A) The satisfaction’’. 

iv. Paragraph (b)(3)(iii)(C) is 

redesignated as new paragraph 

(b)(3)(iii)(B) and the first line of the 

newly redesignated paragraph is 

corrected to read ‘‘(B) The satisfaction’’. 

114. On page 75210, in the third 

column, in the first partial paragraph, 

paragraph (c)(4)(iv)(A), in the last line of 

the paragraph, the language ‘‘See 

§ 1.56A–1(d)(3).’’ is removed. 

115. On page 75211, in the first 

column, paragraph (c)(6) is redesignated 

as paragraph (c)(7) and new paragraph 

(c)(6) is added to read as follows: 

* * * * * 

(c) * * * 

(6) Exclusion from AFSI. For purposes 

of determining the AFSI of a CAMT 

entity, the CAMT entity disregards the 

total amount of income reflected in its 

FSI resulting solely from the discharge 

of indebtedness of the CAMT entity to 

the extent that payment of the liability 

would have given rise to a direct 

reduction in AFSI. 

* * * * * 

116. On page 75211, in the first 

column, in newly redesignated 

paragraph (c)(7), the last line of the 

introductory text is corrected to read ‘‘of 

a tax consolidated group, and the 

exclusion in paragraph (c)(6) of this 

section does not apply.’’. 

117. On page 75211, in the first 

column, in newly redesignated 

paragraph (c)(7)(i)(A), the third line up 

from the bottom of the paragraph is 

corrected to read ‘‘the discharge of 

indebtedness. X has no other items of 

income, gain, deduction, or loss for its 

2024 taxable year. Y’’. 

118. On page 75211, in the second 

column, in newly redesignated 

paragraph (c)(7)(ii)(A), in the fourth line 

down from the top of the paragraph, the 

language ‘‘paragraph (c)(6)(i)(A)’’ is 

corrected to read ‘‘paragraph 

(c)(7)(i)(A)’’. 

119. On page 75211, in the third 

column, in newly redesignated 

paragraph (c)(7)(iv)(A), in the fifth line 

down from the top of the paragraph, the 

language ‘‘(c)(6)(iii)(A)’’ is corrected to 

read ‘‘(c)(7)(iii)(A)’’. 

120. On page 75211, in the third 

column, in newly redesignated 

paragraph (c)(7)(iv)(B), the tenth line 

down from the top of the paragraph is 

corrected to read ‘‘of computing its 

AFSI. See id. X then uses its FSNOL to 

reduce its AFSI by $120x. See § 1.56A– 

23(c). X’s’’ 

121. On page 75211, in the third 

column, in paragraph (d)(2)(i), the last 

line on the page is corrected to read 

‘‘General rule. Solely with regard to 

the’’. 

122. On page 75212, in the first 

column, in paragraph (d)(2)(i), the first 

five lines of the page are corrected to 

read ‘‘emergence from bankruptcy by a 

CAMT entity, the CAMT entity 

determines its CAMT consequences 

resulting from that emergence (and not 

as the result of a discharge of 

indebtedness or covered recognition 

transaction, as provided in paragraphs 

(d)(2)(ii) and (iii) of this section) by—’’. 

§ 1.56A–22 [Corrected] 

123. On page 75214, in the first 

column, in paragraph (c)(2)(ii), in the 

eleventh line up from the bottom of the 

paragraph, the word ‘‘section’’ is 

removed. 

§ 1.56A–23 [Corrected] 

124. On page 75215, in the third 

column, paragraph (e)(2)(i) is corrected 

to read ‘‘(i) A transaction described in 

section 381(a) of the Code; or’’. 

125. On page 75216, in the first 

column, in paragraph (e)(3)(i)(B), the 

last line of the paragraph is corrected to 

read ‘‘section and the exceptions in 

paragraph (e)(3)(v) of this section.’’. 

126. On page 75216, in the third 

column, the paragraph heading of 

paragraph (e)(4)(i) is corrected to read 

‘‘(i) Example 1: Acquisition of Target 

stock followed by contribution—’’. 

127. On page 75216, in the third 

column, in paragraph (e)(4)(i)(A): 

i. In the seventh line up from the 

bottom of the paragraph, the language 

‘‘assets’’ is corrected to read ‘‘assets that 

do not constitute a line of business’’. 

ii. In the sixth line up from the bottom 

of the paragraph, the language 

‘‘(Expansion)’’ is corrected to read 

‘‘(Contribution)’’. 

iii. In the fifth line up from the bottom 

of the paragraph, the language 

‘‘Expansion’’ is corrected to read 

‘‘Contribution’’. 

128. On page 75218, in the second 

column, in paragraph (f)(4)(iii), in the 

third line up from the bottom of the 

paragraph, the language ‘‘RBIL’’ is 


ddrumheller on DSK120RN23PROD with PROPOSALS1
Federal Register / Vol. 89, No. 247 / Thursday, December 26, 2024 / Proposed Rules 104915 

corrected to read ‘‘recognized built-in 

loss’’. 

129. On page 75218, in the second 

column, in paragraph (f)(5)(i); 

i. In the eighth line up from the 

bottom of the paragraph, the language 

‘‘an unrealized loss’’ is corrected to read 

‘‘a built-in loss’’. 

ii. In the sixth line up from the bottom 

of the paragraph, the language ‘‘an 

unrealized gain’’ is corrected to read ‘‘a 

built-in gain’’. 

§ 1.56A–26 [Corrected] 

130. On page 75221, in the third 

column, in paragraph (d)(1), the fourth 

and fifth lines up from the bottom of the 

paragraph are corrected to read, ‘‘CAMT 

entity must adjust its AFSI with respect 

to that transaction to reflect’’. 

§ 1.59–2 [Corrected] 

131. On page 75223, in the third 

column, in paragraph (c)(2)(ii)(B), in the 

sixth line down from the top of the 

paragraph, the language ‘‘(c)(2)(i)(C)’’ is 

corrected to read ‘‘(c)(2)(ii)(C)’’. 

132. On page 75226, in the first and 

second columns, paragraph (f)(2)(i) is 

corrected to read as follows: 

* * * * * 

(f) * * * 

(2) * * * 

(i) In general—(A) Corporation 

experiencing ownership change. For 

purposes of paragraph (f)(1) of this 

section, if a corporation experiences a 

change in ownership during a taxable 

year that results in the corporation and 

a person no longer being treated as 

related under the relevant relationship 

criteria, then following the change in 

ownership— 

(1) The corporation retains its AFSI 

for any relevant period prior to the 

change in ownership to determine 

whether the corporation meets the 

average annual AFSI test (as described 

in paragraph (c) of this section) for the 

taxable year in which the change in 

ownership occurs or for any subsequent 

taxable year; but 

(2) The corporation does not include 

that person’s AFSI in the corporation’s 

AFSI for any period prior to the change 

in ownership (notwithstanding that the 

corporation and the person were treated 

as related under the relevant 

relationship criteria during some, or all, 

of that period) to determine whether the 

corporation meets the average annual 

AFSI test for the taxable year in which 

the change in ownership occurs or for 

any subsequent taxable year in which 

the corporation and the person are not 

treated as related under the relevant 

relationship criteria. 

(B) Person related to corporation 

following ownership change. Following 

a corporation’s change in ownership, 

each person treated as related to the 

corporation under the relevant 

relationship criteria determines whether 

it meets the average annual AFSI test (if 

applicable) for the taxable year in which 

the change in ownership occurs or for 

any subsequent taxable year by 

separately applying the rules in this 

paragraph (f). For example, such person 

does not include the corporation’s AFSI 

in the person’s AFSI for any relevant 

period prior to the corporation’s change 

in ownership if the corporation and the 

person were never previously related 

under the relevant relationship criteria. 

For the avoidance of doubt, such person 

includes the corporation’s AFSI in its 

AFSI for any relevant period following 

the change in ownership during which 

the parties are related under the relevant 

relationship criteria, unless paragraph 

(f)(2)(i)(A) of this section applies. 

(C) Change in ownership. For 

purposes of paragraphs (f)(2)(i)(A) and 

(B) of this section, a corporation 

experiences a change in ownership 

during a taxable year of the corporation 

if— 

(1) The corporation is not a test group 

parent (as defined in paragraph (b)(7) of 

this section); 

(2) The corporation is treated as 

related to a test group parent under the 

relevant relationship criteria as of the 

first day of the taxable year; and 

(3) As a result of a transaction (or 

series of related transactions) the 

corporation and the test group parent no 

longer satisfy the relevant relationship 

criteria as of the last day of the taxable 

year. 

* * * * * 

133. On page 75227, in the first, 

second, and third columns, in 

paragraphs (f)(3)(i)(D) and (E) and 

(f)(3)(ii)(C), the reference ‘‘(b)(6)’’ is 

corrected to read, ‘‘(b)(7)’’, everywhere it 

appears. 

134. On page 75228, in the first 

column, in paragraph (g)(2)(iii)(B), the 

second and third lines down from the 

top of the paragraph are corrected to 

read, ‘‘than the AFSI adjustments in 

§§ 1.56A–8(b), 1.56A–14, and, solely for 

purposes of’’. 

§ 1.1502–56A [Corrected] 

135. On page 75238, in the second 

column, in paragraph (d)(3)(i): 

i. The fifth and sixth lines up from the 

bottom of the paragraph are corrected to 

read, ‘‘beginning after December 31, 

2019. For each share of stock of a’’. 

ii. The second line up from the 

bottom of the paragraph is corrected to 

read ‘‘(shareholder member) on the first 

day of the first taxable year beginning 

after December 31, 2019, the CAMT 

basis of such share equals the sum’’. 

136. On page 75238, in the second 

column, in paragraph (d)(3)(ii): 

i. In the fifth line up from the bottom 

of the paragraph, the language ‘‘The 

CAMT basis in a’’ is corrected to read 

‘‘For each’’. 

ii. The last line of the paragraph is 

corrected to read ‘‘consolidated group 

after the first day of the first taxable year 

beginning after December 31, 2019, the 

CAMT basis of such share equals the 

sum of:’’. 

137. On page 75238, in the second 

column, in paragraph (d)(3)(iii)(A), in 

the fourth line up from the bottom of the 

page, the word ‘‘including’’ is corrected 

to read ‘‘incorporating’’. 

138. On page 75239, in the first 

column, in paragraph (e)(4)(i)(B), the 

third line up from the bottom of the 

paragraph is corrected to read 

‘‘elimination)). Accordingly, the P 

Group’s’’. 

139. On page 75240, in the third 

column, in paragraph (f)(6)(ii), the sixth 

and fifth lines up from the bottom of the 

paragraph are corrected to read 

‘‘apportioned to M2 (($20x/($20x + $40x 

+ $5x)) × $55x = $16.9x). See’’. 

140. On page 75243, in the first 

column, in paragraph (j)(3)(ii), the 

second to last and last lines of the 

paragraph are corrected to read ‘‘is 

apportioned to T (($200x/($200x + 

$1,000x)) × $165x = $27.5x).’’. 

Kalle L. Wardlow, 

Federal Register Liaison, Publications & 

Regulations Section, Associate Chief Counsel, 

(Procedure and Administration). 

[FR Doc. 2024–29958 Filed 12–23–24; 8:45 am] 

BILLING CODE 4830–01–P 

DEPARTMENT OF THE TREASURY 

Office of the Secretary 

31 CFR Part 10 

[REG–116610–20] 

RIN 1545–BQ12 

Regulations Governing Practice Before 

the Internal Revenue Service 

AGENCY: Office of the Secretary, 

Treasury. 

ACTION: Notice of proposed rulemaking, 

notice of public hearing, and 

withdrawal of notice of proposed 

rulemaking. 

SUMMARY: This document contains 

proposed amendments to the 

regulations governing practice before 

the IRS. These regulations propose to 

eliminate provisions related to 


ddrumheller on DSK120RN23PROD with PROPOSALS1