Introduction›Section 351. The conclusion in Rev.
Section 7872.—Treatment of Loans With Below-Market Interest Rates
Internal Revenue Bulletin 2006-2 · 2026-10-03 edition · updated 2026-10-04 · United States
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of January 2006. See Rev. Rul. 2006-4, page 264.
comes a TYK will remain an eligible entity for purposes of § 301.7701–1 through 3.
HOLDING
A Japanese YK that becomes a Japanese TYK, pursuant to the Company Law and the Coordination Law, as promulgated on July 26, 2005, will remain an eligible entity for purposes of § 301.7701–1 through 3.
DRAFTING INFORMATION
The principal author of this revenue ruling is Ronald M. Gootzeit of the Office of Associate Chief Counsel (International). For further information regarding this revenue ruling, contact Ronald M. Gootzeit at (202) 622–3860 (not a toll-free call).
2006–2 I.R.B. 277 January 9, 2006
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