This PDF is the current document as it appeared on Public Inspection on 09/16/2016 at 08:45 am.
Internal Revenue Service (IRS), Treasury.
This document contains corrections to final regulations (TD 9773) that were published in the Federal Register on Thursday, June 30, 2016 (81 FR 42482). This document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.
This correction is effective September 19, 2016 and is applicable on or after June 30, 2016.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Melinda E. Harvey of the Office of Associate Chief Counsel (International) at (202) 317-6934 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations (TD 9773) that are the subject of this correction are under section 1.6038-4 of the Internal Revenue Code.
Need for Correction
As published, the final regulations (TD 9773) contain 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
- Income taxes
- Reporting and recordkeeping requirements
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:Start Part
PART 1—INCOME TAXESEnd Part Start Amendment Part
Paragraph 1. The authority citation for part 1 continues to read in part as follows:End Amendment Part Start Amendment Part
Par. 2. Section 1.6038-4 is amended by revising paragraph (d)(3)(iv) to read as follows:End Amendment Part
(d) * * *
(3) * * *
(iv) Income tax paid and accrued tax expense of permanent establishment. In the case of a constituent entity that is a permanent establishment, the amount of income tax paid and the amount of accrued tax expense referred to in paragraphs (d)(2)(iv) and (v) of this section should not include the income tax paid or tax expense accrued by the business entity of which the permanent establishment would be a part, but for the third sentence of paragraph (b)(2) of this section, in that business entity's tax jurisdiction of residence on the income derived by the permanent establishment.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-22440 Filed 9-16-16; 8:45 am]
BILLING CODE 4830-01-P