[Federal Register: December 27, 2006 (Volume 71, Number 248)]
[Proposed Rules]
[Page 77654-77655]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr27de06-28]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-208270-86]
RIN 1545-AM12
Income and Currency Gain or Loss With Respect to a Section 987
QBU; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to notice of proposed rulemaking.
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SUMMARY: This document contains corrections to a notice of proposed
rulemaking that was published in the Federal Register on Thursday,
September 7, 2006 (71 FR 52876), regarding the determination of the
items of income or loss of a taxpayer with respect to a section 987
qualified business unit as well as the timing, amount, character and
source of any section 987 gain or loss.
FOR FURTHER INFORMATION CONTACT: Sheila Ramaswamy, (202) 622-3870 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking (REG-208270-86) that is the
subject of these corrections is under section 987 of the Internal
Revenue Code.
Need for Correction
As published, the notice of proposed rulemaking (REG-208270-86)
contains errors that may prove to be misleading and is in need of
clarification.
Correction of Publication
Accordingly, the notice of proposed rulemaking (REG-208270-86),
that was the subject of FR Doc. 06-7250, is corrected as follows:
1. On page 52879, second column, in the preamble under the
paragraph heading ``E. Concerns Regarding the 1991 Proposed
Regulations: Notice 2000-20,'' the sixteenth line following the
formula, the language ``DE. The DE conducts mineral'' is corrected to
read ``DE. The DE conducts mineral extraction in Country X''.
2. On page 52886, first column, in the preamble under the paragraph
heading ``C. Section 1.987-3 Determination of the Items of Section 987
Taxable Income or Loss of an Owner of a Section 987 QBU,'' the eighth
line, the language ``under other provisions are not taken'' is
corrected to read ``under other provisions of the Code or regulations
are not taken''.
3. On page 52886, second column, under the paragraph heading ``C.
Section 1.987-3 Determination of the Items of Section 987 Taxable
Income or Loss of an Owner of a Section 987 QBU,'' first full
paragraph, ninth line from the bottom of the paragraph, the language
``rates for amount realized and adjusted'' is corrected to read ``rates
for the amount realized and adjusted''.
4. On page 52886, second column, under the paragraph heading ``C.
Section 1.987-3 Determination of the Items of Section 987 Taxable
Income or Loss of an Owner of a Section 987 QBU,'' second full
paragraph, fifth line, the language ``Generally the amount realized
and'' is corrected to read ``Generally, the amount realized and
adjusted''.
Sec. 1.987-1 [Corrected]
5. On page 52895, second column, Sec. 1.987-1(b)(7), paragraph
(ii)(B) of Example 1, fifth line from the bottom of the paragraph, the
language ``neither the activities of DE1 or DE2 are'' is corrected to
read ``the activities of DE1 are not''.
Sec. 1.987-2 [Corrected]
6. On page 52899, first column, Sec. 1.987-2(c)(9), lines 2 and 3,
the language ``illustrate the principles of this paragraph (c). For
purposes of these'' is corrected to read ``illustrate the principles of
paragraph (b) of this section and this paragraph (c). For purposes of
these''.
[[Page 77655]]
7. On page 52899, second column, Sec. 1.987-2(c)(9), paragraph
(ii)(B) of Example 1, last line, the language ``section 988 to X as a
result of the loan.'' is corrected to read ``section 988 to X as a
result of the disregarded loan.''
8. On page 52899, third column, Sec. 1.987-2(c)(9), paragraph
(ii)(A) of Example 3, line 3, the language ``Federal tax purposes and
therefore is a'' is corrected to read ``Federal income tax purposes and
therefore is a''.
9. On page 52900, first column, Sec. 1.987-2(c)(9), paragraph
(ii)(C) of Example 4, line 3, the language ``regarded for U.S. Federal
tax purposes. As a'' is corrected to read ``regarded for U.S. Federal
income tax purposes. As a''.
10. On page 52900, second column, Sec. 1.987-2(c)(9), paragraph
(ii)(A) of Example 7, line 1, the language ``(ii) Analysis. (A) For
Federal tax purposes'' is corrected to read ``(ii) Analysis. (A) For
Federal income tax purposes''.
11. On page 52901, third column, Sec. 1.987-2(d)(2), line 3, the
language ``described in section 988(c)(1)(i) and (ii)'' is corrected to
read ``described in section 988(c)(1)(B)(i) and (ii)''.
Sec. 1.987-3 [Corrected]
12. On page 52902, third column, Sec. 1.987-3(e)(2), line 5, the
language ``described in section 988(c)(1)(A)(i) and'' is corrected to
read ``described in section 988(c)(1)(B)(i) and''.
13. On page 52904, first column, Sec. 1.987-3(f) Example 3., the
fourth line from the bottom of the paragraph, the language ``section
and Sec. 1.987-1(c)(3) [euro]8,000 x $1='' is corrected to read
``section and Sec. 1.987-1(c)(3) ([euro]8[n1],000 x $1=''.
Sec. 1.987-6 [Corrected]
14. On page 52911, first column, Sec. 1.987-6(c) Example, lines 5
through 10 from the bottom of the column, the language ``of this
section, Sf7,500 (Sf750,000/Sf1,000,000 x Sf10,000) of the section 987
gain will be treated as foreign source general limitation income which
is not subpart F income and Sf2,500 (Sf250,000/Sf1,000,000 x Sf10,000)
will'' is corrected to read ``of this section, Sf7,500 ((Sf750,000/
Sf1,000,000) x Sf10,000) of the section 987 gain will be treated as
foreign source general limitation income which is not subpart F income
and Sf2,500 ((Sf250,000/Sf1,000,000) x Sf10,000) will''.
Cynthia E. Grigsby,
Senior Federal Register Liaison Officer, Publications and Regulations
Branch, Legal Processing Division, Associate Chief Counsel (Procedure
and Administration).
[FR Doc. E6-22169 Filed 12-26-06; 8:45 am]
BILLING CODE 4830-01-P