Internal Revenue Bulletin: 2006-45 |
November 6, 2006 |
Determination of Interest Expense Deduction of Foreign Corporations; Correction
Table of Contents
This document contains a correction to final and temporary regulations (T.D. 9281, 2006-39 I.R.B. 517), that were published in the Federal Register on Thursday, August 17, 2006 (71 FR 47443). This regulation revised the Income Tax Regulations relating to the determination of the interest expense deduction of foreign corporations and applies to foreign corporations engaged in a trade or business within the United States.
Gregory Spring or Paul Epstein, (202) 622-3870 (not a toll-free number).
The final and temporary regulations (T.D. 9281) that is the subject of this correction are under sections 882 and 884 of the Internal Revenue Code.
As published, T.D. 9281 contains errors that may prove to be misleading and are in need of clarification.
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Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 USC 7805 * * *
Par. 2. Section 1.882-5 paragraph (a)(7) is revised to read as follows:
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(a)(7) through (a)(7)(iii) [Reserved]. For further guidance, see entry in § 1.882-5T(a)(7) through (a)(7)(iii).
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Par. 3. Section 1.882-5T is amended by revising the last sentence of paragraph (c)(2)(iv) to read as follows:
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(c) * * *
(2) * * *
(iv)* * * The rules of § 1.882-5(b)(3) apply in determining the total value of applicable worldwide assets for the taxable year, except that the minimum number of determination dates are those stated in § 1.882-5(c)(2)(i).
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Cynthia E. Grigsby,
Senior
Federal Register Liaison Officer,
Publications and Regulations
Branch,
Legal Processing Division,
Associate
Chief Counsel
(Procedure and Administration).
Note
(Filed by the Office of the Federal Register on September 27, 2006, 8:45 a.m., and published in the issue of the Federal Register for September 28, 2006, 71 F.R. 56868)
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