Internal Revenue Service (IRS), Treasury.
This document contains a correction to temporary regulations (TD 9508) that were published in the Federal Register on Wednesday, December 8, 2010 (75 FR 76262)providing guidance about the treatment of fails charges for purposes of sections 871 and 881, which generally require gross-basis taxation of foreign persons not otherwise subject to U.S. net-basis taxation and the withholding of such tax under sections 1441 and 1442.
This correction is effective on December 28, 2010, and is applicable beginning December 8, 2010.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Sheila Ramaswamy or Anthony J. Marra at (202) 622-3870 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The temporary regulations (TD 9508) that are the subject of this document are under section 863 of the Internal Revenue Code.
Need for Correction
As published, the temporary regulations (TD 9508) contain an error that may prove to be misleading and is in need of clarification.Start List of Subjects
List of Subject 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) Expiration date. This section expires on December 6, 2013.
Guy R. Traynor,
Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration.
[FR Doc. 2010-32536 Filed 12-27-10; 8:45 am]
BILLING CODE 4830-01-P