Internal Revenue Service (IRS), Treasury.
This document contains a correction to final and temporary regulations
(T.D. 9281, 2006-39 I.R.B. 517), that were published in the Federal
Register on Thursday, August 17, 2006 (71 FR 47443). This regulation
revised the Income Tax Regulations relating to the determination of the interest
expense deduction of foreign corporations and applies to foreign corporations
engaged in a trade or business within the United States.
This correction is effective August 17, 2006.
FOR FURTHER INFORMATION CONTACT:
Gregory Spring or Paul Epstein, (202) 622-3870 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
The final and temporary regulations (T.D. 9281) that is the subject
of this correction are under sections 882 and 884 of the Internal Revenue
Code.
As published, T.D. 9281 contains errors that may prove to be misleading
and are in need of clarification.
* * * * *
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting
amendment:
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 USC 7805 * * *
Par. 2. Section 1.882-5 paragraph (a)(7) is revised to read as follows:
§ 1.882-5 Determination of interest deduction.
* * * * *
(a)(7) through (a)(7)(iii) [Reserved]. For further guidance, see entry
in § 1.882-5T(a)(7) through (a)(7)(iii).
* * * * *
Par. 3. Section 1.882-5T is amended by revising the last sentence of
paragraph (c)(2)(iv) to read as follows:
§ 1.882-5T Determination of interest deduction
(temporary).
* * * * *
(c) * * *
(2) * * *
(iv)* * * The rules of § 1.882-5(b)(3) apply in determining
the total value of applicable worldwide assets for the taxable year, except
that the minimum number of determination dates are those stated in § 1.882-5(c)(2)(i).
* * * * *
Cynthia E. Grigsby,
Senior
Federal Register Liaison Officer,
Publications and Regulations
Branch,
Legal Processing Division,
Associate
Chief Counsel
(Procedure and Administration).
Note
(Filed by the Office of the Federal Register on September 27, 2006,
8:45 a.m., and published in the issue of the Federal Register for September
28, 2006, 71 F.R. 56868)
You can either: Search all IRS Bulletin Documents issued since January 1996, or Search the entire site. For a more focused search, put your search word(s) in quotes.
