Rev. Rul. 64-291

With respect to any liability to file a return, Form 959 (Rev. Jan. 1963), United States Information Return with Respect to the Organization or Reorganization of a Foreign Corporation and Acquisition of its Stock, under section 6046(a)(1) of the Internal Revenue Code of 1954 arising after January 1, 1963, if-

(1) As a result of an acquisition of stock of a foreign corporation, a United States person files a return as a shareholder under section 6046(a)(2) of the Code, and

(2) Immediately after such acquisition, three or fewer United States persons own 95 percent or more in value of the outstanding stock of such foreign corporation,

then, with respect to such acquisition, no return shall be required under section 6046(a)(1) of the Code, of a United States citizen or resident who is an officer or director of such corporation.

The reason for this construction is that the return of the shareholder discloses all the information required of the officer or director.

Conforming amendments to the regulations are under consideration.

Revenue Ruling 63-116, C.B. 1963-1, 293, is hereby modified to make its provisions applicable to situations where liability to file returns under section 6046(a)(1) of the Code arises after January 1, 1963.

¹ Based on Technical Information Release 630, dated September 16, 1964.