[Federal Register Volume 65, Number 237 (Friday, December 8, 2000)]
[Rules and Regulations]
[Pages 76932-76933]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-31255]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 8889]
RIN 1545-AV10


Guidance Regarding Claims for Certain Income Tax Convention 
Benefits; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

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SUMMARY: This document contains corrections to final regulations (TD 
8889) which were published in the Federal Register on Monday, July 3, 
2000 (65 FR 40993). The final regulations relate to claims for certain 
income tax convention benefits.

DATES: This correction is effective July 3, 2000.

FOR FURTHER INFORMATION CONTACT: Shawn R. Pringle (202) 622-3850 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations that are subject to these corrections are 
under section 894 of the Internal Revenue Code.

Need for Correction

    As published, final regulations (TD 8889) contains errors that may 
prove to be misleading and are in need of clarification.

Correction of Publication

    Accordingly, the publication of final regulations (TD 8889),which 
was the subject of FR Doc. 00-16761, is corrected as follows:
    1. On page 40996, column 2, in the preamble under the paragraph 
heading ``D. Treatment of Complex Trusts'', paragraph 2, line 13 from 
the bottom of the paragraph, the language ``the hands of the interest 
holder are'' is corrected to read ``the hands of the interest holder 
are not''.
    2. One page 40997, column 1, in the preamble under the paragraph 
heading ``Special Analyses'', paragraph 1, line 2, the language 
``treasury decision not a significant'' is corrected to read ``Treasury 
decision is not a significant''.


Sec. 1.894-1  [Corrected]

    3. On page 40997, column 1, correct the amendatory instruction for 
Par. 2. to read as follows:

    Par. 2. Section 1.894-1 is amended as follows:
    1. Paragraph (d) is redesignated as paragraph (e), and a new 
paragraph (d) is added.
    2. In newly designated paragraph (e), add a sentence at the end of 
the paragraph.
    The additions read as follows:
    4. On page 40999, column 2, Sec. 1.894-1(d)(5), paragraph (i) of 
Example 7., line 10, the language ``legal personality of the 
arrangement, A is not'' is corrected to read ``legal personality in 
Country X of the arrangement, A is not''.
    5. On page 40999, column 2, Sec. 1.894-1(d)(5), paragraph (i) of 
Example 7., lines 11 and 12, the language ``liable to tax at the entity 
level of Country X and is not a resident within the meaning of'' is 
corrected to read ``liable to tax as a person at the entity level in 
Country X and is thus not a resident within the meaning of''.
    6. On page 40999, column 2, Sec. 1.894-1(d)(5), paragraph (ii) of 
Example 7., line 9, the language ``is not considered a resident of 
Country X'' is corrected to read ``is not considered a person in 
Country X and thus not a resident of Country X''.
    7. On page 40999, column 2, Sec. 1.894-1(d)(5), paragraph (ii) of 
Example 7., line 12, the language ``derive the income for purposes of 
the U.S.-'' is corrected to read ``derive the income as a resident of 
Country X for purposes of the U.S.-''.
    8. On page 41000, column 1, Sec. 1.894-1(d)(5), paragraph (i) of 
Example 11., the last line of the paragraph, the language ``subject to 
tax by Country X.'' is corrected to read ``taxed by Country X.''.
    9. On page 41000, column 2, Sec. 1.894-1, after paragraph (d)(6), 
add a sentence at the end of paragraph (e) to read as follows:


Sec. 1.894-1  Income affected by treaty.

* * * * *
    (e) * * * See paragraph (d)(6) of this section for applicability 
dates for paragraph (d) of this section.
    10. On page 41000, column 2, a new amendatory instruction Par. 3. 
is added to read as follows:

[[Page 76933]]

Sec. 1.894-1T  [Removed]

    Par. 3. Section 1.894-1T is removed.

Cynthia E. Grigsby,
Chief, Regulations Unit, Office of Special Counsel (Modernization & 
Strategic Planning).
[FR Doc. 00-31255 Filed 12-7-00; 8:45 am]
BILLING CODE 4830-01-U