[Federal Register Volume 71, Number 246 (Friday, December 22, 2006)]
[Rules and Regulations]
[Pages 76913-76914]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E6-21907]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 31

[TD 9278]
RIN 1545-BB31, 1545-AY38, 1545-BC52


Treatment of Services Under Section 482; Allocation of Income and 
Deductions From Intangibles; Stewardship Expense; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

[[Page 76914]]


ACTION: Correction to final and temporary regulations.

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SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9278) that was published in the Federal Register on 
Friday, August 4, 2006 (71 FR 44466) regarding the treatment of 
controlled services transactions under section 482 and the allocation 
of income from intangibles, in particular with respect to contributions 
by a controlled party to the value of an intangible owned by another 
controlled party. This document also contains corrections to final and 
temporary regulations that modify the regulations under section 861 
concerning stewardship expenses to be consistent with the changes made 
to the regulations under section 482.

DATES: This correction is effective January 1, 2007.

FOR FURTHER INFORMATION CONTACT: Thomas A. Vidano, (202) 435-5265, or 
Carol B. Tan, (202) 435-5159, for matters relating to section 482, and 
David F. Bergkuist, (202) 622-3850, for matters relating to stewardship 
expenses (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations (TD 9278) that are the subject 
of these corrections is under sections 482 and 861 of the Internal 
Revenue Code.

Need for Correction

    As published, final and temporary regulations (TD 9278) contain 
errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, final and temporary regulations (TD 9278) that were 
the subject of FR Doc. 06-6497 are corrected as follows:
    1. On page 44466, column 1, in the heading, the subject ``Treatment 
of Services Under Section 482; Allocation of Income and Deductions From 
Intangibles; Stewardship Expense'' is corrected to read ``Treatment of 
Services Under Section 482; Allocation of Income and Deductions From 
Intangibles; and Apportionment of Stewardship Expense''.
    2. On page 44470, column 2, in the preamble under the paragraph 
heading ``5. Comparable Profits Method for Services--Temp. Treas. Reg. 
Sec.  1.482-9T(f)'', fifth line from the top of the column, the 
language ``assets play a greater role in general'' is corrected to read 
``assets play a greater role in generating''.
    3. On page 44475, column 3, in the preamble under the paragraph 
heading ``Services Subject to a Qualified Cost Sharing Arrangement--
Temp. Treas. Reg. Sec.  1.482-9T(m)(3),'' fourth line from the top of 
the column, the language ``two provisions, the rule Sec.  1.482-'' is 
corrected to read ``two provisions, the rule in Sec.  1.482-''.

Cynthia Grigsby,
Senior Federal Register Liaison Officer, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E6-21907 Filed 12-21-06; 8:45 am]
BILLING CODE 4830-01-P