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Rule

Determination of Interest Expense Deduction of Foreign Corporations; Correction

A Rule by the Internal Revenue Service on 09/28/2006

Document Details

Information about this document as published in the Federal Register.

Printed version:
PDF
Publication Date:
09/28/2006
Agencies:
Internal Revenue Service
Dates:
This correction is effective August 17, 2006.
Effective Date:
08/17/2006
Document Type:
Rule
Document Citation:
71 FR 56868
Page:
56868 (1 page)
CFR:
26 CFR 1
Agency/Docket Number:
TD 9281
RIN:
1545-BF70
Document Number:
E6-15893
Document Details
Published Document

This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.

Start Preamble

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document contains a correction to final and temporary regulations (TD 9281), 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.

DATES:

This correction is effective August 17, 2006.

Start Further Info

FOR FURTHER INFORMATION CONTACT:

Gregory Spring or Paul Epstein, (202) 622-3870 (not a toll-free number).

End Further Info End Preamble Start Supplemental Information

SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations (TD 9281) that is the subject of this correction are under sections 882 and 884 of the Internal Revenue Code.

Need for Correction

As published, TD 9281 contains errors that may prove to be misleading and are in need of clarification.

Start List of Subjects

List of Subjects in 26 CFR Part 1

End List of Subjects

Correction of Publication

Start Amendment Part

Accordingly,

End Amendment Part Start Part

PART 1—INCOME TAXES

End Part Start Amendment Part

End Amendment Part Start Authority

Authority: 26 U.S.C. 7805 * * *

End Authority Start Amendment Part

End Amendment Part
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).

* * * * *
Start Amendment Part

End Amendment Part
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).

* * * * *
Start Signature

Cynthia E. Grigsby,

Senior Federal Register Liaison Officer, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

End Signature End Supplemental Information

[FR Doc. E6-15893 Filed 9-27-06; 8:45 am]

BILLING CODE 4830-01-P

Published Document