Prop. Treas. Reg. § 1.986(a)-1 [Amended].

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 986(a) · Would amend § 1.986(a)-1

Par. 34. Section 1.986(a)-1 is amended by: 1. In paragraph (c), removing the language “PTEP group taxes (as defined in § 1.960-3(d)(1))” from the first sentence and adding the language “the corporate PTEP tax pool (as defined in § 1.959-1(b)) or any covered shareholder's PTEP tax pool (as defined in § 1.959-1(b))” in its place. 2. In paragraph (e)(1) removing the language “PTEP group taxes” and adding the language “a PTEP tax pool” in its place. 3. In paragraph (e)(2) removing the language “PTEP group taxes (as defined in § 1.960-3(d)(1))” in the first sentence and adding the language “the corporate PTEP tax pool (as defined in § 1.959-1(b)) or any covered shareholder's PTEP tax pool (as defined in § 1.959-1(b))” in its place, and removing the language “PTEP group taxes” in the second sentence and adding the language “a PTEP tax pool” in its place. 4. In paragraph (e)(3) removing the language “PTEP group taxes” in the last sentence and adding the language “a PTEP tax pool” in its place. Par. 35. Section 1.986(c)-1 is revised to read as follows: