# Prop. Treas. Reg. § 1.1473-1: Section 1473 definitions.

Proposed regulation, not in force. REG-133673-15, 81 FR 21795, published 2016-04-13 <https://www.federalregister.gov/documents/2016/04/13/2016-08248/deemed-distributions-under-section-305c-of-stock-and-rights-to-acquire-stock>. Interprets 26 U.S.C. § 1473.

Par. 12. Section 1.1473-1 is amended by: 1. Amending paragraph (a)(2)(vii)(A) by adding a sentence to the end of the paragraph. 2. Adding paragraph (d)(7). 3. Amending paragraph (f) by adding a third and fourth sentence. The additions read as follows:

(a) * * *

(2) * * *

(vii) * * *

(A) * * * For purposes of determining the amount of a deemed distribution (as defined in § 1.305-1(d)(7)) on a specified security (as defined in § 1.6045-1(a)(14)) or a deemed payment (as defined in § 1.861-3(a)(6)) that is determined with respect to a deemed distribution on a specified security, a withholding agent other than the issuer of the specified security may rely on issuer reporting by applying the rule under § 1.1441-3(c)(5)(i) to deemed distributions or deemed payments that are withholdable payments under chapter 4.

* * * * *

(d) * * *

(7) Withholding agent with respect to deemed distributions under section 305(c). Any person that issues or holds directly or indirectly (for example, through an account maintained for another intermediary) on behalf of a beneficial owner or a flow through entity that owns directly or indirectly (through another flow-through entity), a security upon which a deemed distribution (as defined in § 1.305-  1(d)(7)) is made has custody of or control over the deemed distribution.

* * * * *

(f) * * * Paragraphs (a)(2)(vii) and (d)(7) of this section apply to payments made on or after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register . A withholding agent may, however, rely on the rules in paragraphs (a)(2)(vii) and (d)(7) of this section for all deemed distributions (as defined in § 1.305-1(d)(7)) or deemed payments (as defined in § 1.861-3(a)(6)) that are withholdable payments occurring on or after January 1, 2016, until the date of publication of a Treasury decision adopting these rules as final regulations in the Federal Register .