Internal Revenue Service (IRS), Treasury.
This document contains corrections to final regulations (TD 9465) that were published in the Federal Register on Monday, September 28, 2009 (74 FR 49315) concerning the determination of the interest expense deduction of foreign corporations engaged in a trade or business within the United States. These final regulations conform the interest expense rules to recent U.S. Income Tax Treaty agreements and adopt other changes to improve compliance.
This correction is effective on November 5, 2009], and is applicable on September 28, 2009.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Anthony J. Marra, (202) 622-3870 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations (TD 9465) that are the subject of this document are under sections 882 and 884 of the Internal Revenue Code.
Need for Correction
As published, the final regulations (TD 9465) contain errors that may prove Start Printed Page 57252to be misleading and are in need of clarification.Start List of Subjects
List of Subjects in 26 CFR Part 1End List of Subjects
Correction of PublicationStart Amendment Part
Accordingly,End Amendment Part Start Part
PART 1—INCOME TAXESEnd Part Start Amendment Part
End Amendment Part Start Amendment Part
End Amendment Part
(f) Effective/applicability date. (1) This section is applicable for taxable years ending on or after August 15, 2009. * * *
End Amendment Part
(e) * * *
(5) * * *
(i) * * * As a result of the election, assuming A's U.S. assets and U.S. liabilities would otherwise have remained constant, A's U.S. net equity as of the close of 2007 will increase by the amount of the decrease in liabilities ($60) from $200 to $260 and its ECEP will be reduced to zero. * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. E9-26274 Filed 11-4-09; 8:45 am]
BILLING CODE 4830-01-P