[Federal Register Volume 71, Number 246 (Friday, December 22, 2006)]
[Proposed Rules]
[Page 76956]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E6-21909]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-146893-02; REG-115037-00; REG-138603-03]
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.

ACTION: Correction to notice of proposed rulemaking by cross-reference 
to temporary regulations, notice of proposed rulemaking, and notice of 
public hearing.

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SUMMARY: This document contains corrections to a notice of proposed 
rulemaking by cross-reference to temporary regulations, notice of 
proposed rulemaking, and notice of public hearing that was published in 
the Federal Register on Friday, August 4, 2006 (71 FR 44247) relating 
to the treatment of controlled services transactions under section 482. 
These regulations also provide guidance regarding 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, as it relates to controlled services transactions, 
and modify the regulations under section 861 concerning stewardship 
expenses to be consistent with the changes made to the regulations 
under section 482.

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 notice of proposed rulemaking (REG-146893-02, REG-115037-00 and 
REG-138603-03) by cross-reference to temporary regulations that is the 
subject of this correction is under section 482 and 861 of the Internal 
Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-146893-02, 
REG-115037-00 and REG-138603-03) by cross-reference to temporary 
regulations contains errors that may prove to be misleading and are in 
need of clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-146893-02, REG-
138603-03 and REG-115037-00) by cross-reference to temporary 
regulations that were the subject of FR Doc. 06-6674, is corrected as 
follows:
    1. On page 44247, column 2, 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 44248, column 2, instructional Par. 3., number 2 is 
corrected to read as follows:
    ``2. Paragraphs (d)(3)(ii)(C), Example 4, Example 5, Example 6 and 
(j)(6) are added.''


Sec.  1.482-1  [Corrected]

    3. On page 44248, column 3, Sec.  1.482-1(j), lines 2 and 3, the 
language ``amendment to Sec.  1.482-1(j) is the same as the text of 
Sec.  1.482-1T(j)(1) and (2)'' is corrected to read ``amendment to 
Sec.  1.482-1(j)(6) is the same as the text of Sec.  1.482-1T(j)(6)''.


Sec.  1.482-8  [Corrected]

    4. On page 44249, column 2, Sec.  1.482-8(a), line 1, the language 
``(a) Example 10. Cost of services plus'' is corrected to read ``(b) * 
* * Example 10. Cost of services plus''.
    5. On page 44249, column 2, Sec.  1.482-8, paragraph (b) following 
Example 12. is removed.


Sec.  1.482-9  [Corrected]

    6. On page 44249, column 2, Sec.  1.482-9(m)(6), last line, the 
language ``operation as defined in Sec.  1.482-8'' is corrected to read 
``operation as defined in the proposed Sec.  1.482-8.''.


Sec.  1.861-8  [Corrected]

    7. On page 44249, column 3, Sec.  1.861-8(f)(4), line 3, the 
language ``same as the text of Sec.  1.861-8T(c)(4)(i)'' is corrected 
to read ``same as the text of Sec.  1.861-8T(f)(4)(i)''.
    8. On page 44249, column 3, Sec.  1.861-8(h), line 3, the language 
``as the text of Sec.  1.861-8T(h)(1) published'' is corrected to read 
``as the text of Sec.  1.861-8T(h) published''.

Cynthia Grigsby,
Senior Federal Register Liaison Officer, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E6-21909 Filed 12-21-06; 8:45 am]
BILLING CODE 4830-01-P