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Proposed Rule

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles

A Proposed Rule by the Internal Revenue Service on 09/08/2010

Document Details

Information about this document as published in the Federal Register.

Printed version:
PDF
Publication Date:
09/08/2010
Agencies:
Internal Revenue Service
Document Type:
Proposed Rule
Document Citation:
75 FR 54541
Page:
54541-54542 (2 pages)
CFR:
26 CFR 1
26 CFR 31
Agency/Docket Number:
REG-146893-02, REG-115037-00
RIN:
1545-BJ32
Document Number:
2010-22239
Document Details
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Enhanced Content

Relevant information about this document from Regulations.gov provides additional context. This information is not part of the official Federal Register document.

Docket Number:
IRS-2009-0015
Enhanced Content
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:

Withdrawal of notice of proposed rulemaking.

SUMMARY:

This document withdraws proposed regulations published in the Federal Register on September 10, 2003 (68 FR 53448), related to the treatment of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible that is owned by another controlled party. The IRS and Treasury Department are withdrawing those proposed regulations because they have been superseded.

Start Further Info

FOR FURTHER INFORMATION CONTACT:

Gregory A. Spring (202) 435-5265 (not a toll-free number).

End Further Info End Preamble Start Supplemental Information

SUPPLEMENTARY INFORMATION:

Background

On September 10, 2003, the Treasury Department and the IRS published in the Federal Register (68 FR 53448, REG-146893-02 and REG-115037-00) proposed regulations relating to the treatment of controlled services transactions and the allocation of income from intangible property, in particular with respect to contributions by a controlled party to the value of intangible property owned by another controlled party. On August 4, 2006, the Treasury Department and the IRS published in the Federal Register (71 FR 44466, TD 9278, REG-146893-02, REG-115037-00, and REG-138603-03) temporary regulations relating to the treatment of controlled services transactions, the allocation of income from intangible property, and stewardship expenses under Treas. Reg. § 1.861-8(e)(4). A notice of proposed rulemaking cross-referencing the temporary regulations was published in the Federal Register on the same day (71 FR 44247). Written comments responding to the notice of proposed rulemaking were received, and a public hearing was held on October 27, 2006. That notice of proposed rulemaking superseded the proposed regulations published in the Federal Register on September 10, 2003.

On August 4, 2009, the Treasury Department and the IRS published in the Federal Register (74 FR 38830, TD 9456) final regulations that are generally consistent with the proposed regulations that were published on August 4, 2006, in the Federal Register (71 FR 44247), and removed the corresponding temporary regulations.

Start List of Subjects

List of Subjects

End List of Subjects

Withdrawal of a Notice of Proposed Rulemaking

Accordingly, under the authority of 26 U.S.C. 7805, the notice of proposed rulemaking (REG-146893-02 and REG-115037-00) published in the Federal Register on September 10, 2003 (68 FR 53448) is withdrawn.

Start Signature

Steven T. Miller,

Deputy Commissioner for Services and Enforcement.

End Signature End Supplemental Information

[FR Doc. 2010-22239 Filed 9-7-10; 8:45 am]

BILLING CODE 4830-01-P

Published Document