[Federal Register Volume 73, Number 146 (Tuesday, July 29, 2008)]
[Rules and Regulations]
[Page 43863]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-17269]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9406]
RIN 1545-BH03


Modifications to Subpart F Treatment of Aircraft and Vessel 
Leasing Income; 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 9406) that was published in the Federal Register on 
Thursday, July 3, 2008 (73 FR 38113) addressing the treatment of 
certain income and assets related to the leasing of aircraft or vessels 
in foreign commerce under sections 367, 954, and 956 of the Internal 
Revenue Code. The regulations reflect statutory changes made by section 
415 of the American Jobs Creation Act of 2004. In general, the 
regulations will affect the United States shareholders of controlled 
foreign corporations that derive income from the leasing of aircraft or 
vessels in foreign commerce and U.S. persons that transfer property 
subject to these leases to a foreign corporation.

DATES: This correction is effective July 29, 2008, and is applicable on 
July 3, 2008.

FOR FURTHER INFORMATION CONTACT: Concerning the temporary regulations 
under section 367, John H. Seibert at (202) 622-3860; concerning the 
temporary regulations under section 954 or 956, Paul J. Carlino at 
(202) 622-3840 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations that are the subjects of this 
document are under sections 367, 954, and 956 of the Internal Revenue 
Code.

Need for Correction

    As published, final and temporary regulations (TD 9406) contain an 
error that may prove to be misleading and is 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 1.954-2(c)(2) is amended by adding paragraph (vii) to 
read as follows:


Sec.  1.954-2  Foreign personal holding company income.

* * * * *
    (c) * * *
    (2) * * *
    (vii) [Reserved]. For further guidance, see Sec.  1.954-
2T(c)(2)(vii).
* * * * *

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E8-17269 Filed 7-28-08; 8:45 am]
BILLING CODE 4830-01-P