There have been 15 unassisted triple plays in the Modern Era of Major League Baseball. The last was in 2009 by Eric Bruntlett, second baseman for my beloved Philadelphia Phillies. Another Phillie, Mickey Morandini, pulled off the feat in 1992. The inning ending play is almost always accomplished with a line drive to the shortstop or second baseman who touches second base (doubling off the runner) and then tags the runner, usually from first base, for the third out. Think of all the innings played in baseball since 1900, and the rarity of the unassisted triple play comes into focus.
Treasury recently identified eight regs to be rescinded or modified. Despite the fact that this action is in response to President Trump’s Executive Order 13789 to review all “significant tax regulations” issued on or after January 1, 2016, its undertaking is quite an anomaly, akin to the scarcity of the unassisted triple play. The eight regs in question follow herein.
- Final §367 regs on certain property transfers to foreign corporations;
- Proposed §103 regs regarding a “political subdivision” eligible to issue tax-exempt bonds;
- Final §987 regs with respect to income and currency gain or loss regarding a qualified business unit;
- Temporary §337(d) regs on transfers of property by C corporations to REITs and RICs;
- Final and temporary §385 regs classifying related party debt or equity;
- Final §7602 regs on Summons Interviews;
- Temporary §752 regs regarding recourse partnership liabilities;
- Proposed §2704 regs on family controlled entities and the elimination of minority discounts and discounts for lack of marketability.
Treasury requests comments on whether these should be rescinded or modified, and if modified, how to reduce burden and complexity.
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Nick Spoltore is Senior Director of Tax & Advisory Content for Surgent CPE. Mr. Spoltore is a graduate of the University of Notre Dame and of Delaware Law School. Before joining Surgent, he practiced tax and business law at the firm of Heaney, Kilcoyne in Pennsylvania and also in Delaware.