This document contains a correction to final regulations (TD 9562) that were published in the Federal Register on Friday, December 9, 2011 (76 FR 76895) providing guidance on conduit financing arrangements. The final regulations apply to multiple-party financing arrangements that are effected through disregarded entities, and are necessary in order to determine which of those arrangements should be recharacterized as a conduit financing arrangement.
This correction is effective on April 16, 2012 and is applicable on December 9, 2011.
FOR FURTHER INFORMATION CONTACT:
Quyen P. Huynh, (202) 622-3880 (not a toll-free number).
The final regulation (TD 9562) that is the subject of this correction is under section 881 of the Internal Revenue Code.
Need for Correction
As published, TD 9562 contains errors that may prove to be misleading and is in need of clarification.
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
PART 1—INCOME TAXES
|Last sentence of paragraph (a)(2)(i)(A)||Examples 1, 2, 3||Examples 1, 2, 3 and 4.|
|Last sentence of paragraph (a)(2)(i)(B)||Examples 4 and 5||Examples 5 and 6.|
|Last sentence of paragraph (a)(3)(ii)(E)(2)(ii)||Example 6||Example 7.|
|Last sentence of paragraph (a)(4)(ii)(B)||Examples 7 and 8||Examples 8 and 9.|
|Last sentence of paragraph (b)(1)||Examples 11 and 12||Examples 12 and 13.|
|Last sentence of paragraph (b)(2)(i)||Examples 13, 14 and 15||Examples 14, 15 and 16.|
|Last sentence of paragraph (b)(2)(iii)||Example 16||Example 17.|
|Last sentence of paragraph (b)(2)(iv)||Example 17||Example 18.|
|Last sentence of paragraph (b)(3)(i)||Examples 21, 22 and 23||Examples 22, 23 and 24.|
|Last sentence of paragraph (d)(1)(i)||Example 24||Example 25.|
|Next to last sentence of paragraph (d)(1)(ii)(A)||Example 25||Example 26.|
|Paragraph (e), Example 21, paragraph (i)||Example 19||Example 20.|
|Paragraph (e), Example 21, paragraph (ii)||Example 20||Example 21.|
|Paragraph (e), Example 23, paragraph (i)||Example 21||Example 22.|
|Paragraph (e), Example 24, paragraph (i)||Example 21||Example 22.|
Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2012-8993 Filed 4-13-12; 8:45 am]
BILLING CODE 4830-01-P