[Federal Register Volume 71, Number 188 (Thursday, September 28, 2006)]
[Rules and Regulations]
[Page 56868]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E6-15893]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9281]
RIN 1545-BF70


Determination of Interest Expense Deduction of Foreign 
Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains a correction to final and temporary 
regulations (TD 9281), 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.

DATES: This correction is effective August 17, 2006.

FOR FURTHER INFORMATION CONTACT: Gregory Spring or Paul Epstein, (202) 
622-3870 (not a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final and temporary regulations (TD 9281) that is the subject 
of this correction are under sections 882 and 884 of the Internal 
Revenue Code.

Need for Correction

    As published, TD 9281 contains errors that may prove to be 
misleading and are in need of clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

0
Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendment:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *

0
Par. 2. Section 1.882-5 paragraph (a)(7) is revised to read as follows:


Sec.  1.882-5  Determination of interest deduction.

* * * * *
    (a)(7) through (a)(7)(iii) [Reserved]. For further guidance, see 
entry in Sec.  1.882-5T(a)(7) through (a)(7)(iii).
* * * * *

0
Par. 3. Section 1.882-5T is amended by revising the last sentence of 
paragraph (c)(2)(iv) to read as follows:


Sec.  1.882-5T  Determination of interest deduction (temporary).

* * * * *
    (c) * * *
    (2) * * *
    (iv) * * * The rules of Sec.  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 Sec.  1.882-5(c)(2)(i).
* * * * *

Cynthia E. Grigsby,
Senior Federal Register Liaison Officer, Publications and Regulations 
Branch, Legal Processing Division, Associate Chief Counsel, (Procedure 
and Administration).
[FR Doc. E6-15893 Filed 9-27-06; 8:45 am]
BILLING CODE 4830-01-P