[Federal Register Volume 74, Number 213 (Thursday, November 5, 2009)]
[Rules and Regulations]
[Page 57252]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-26272]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 602

[TD 9465]
RIN 1545-BF71


Determination of Interest Expense Deduction of Foreign 
Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

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SUMMARY: This document contains a correction to final regulations (TD 
9465) that were published in the Federal Register on Monday, September 
28, 2009 (74 FR 49315) concerning the determination of the interest 
expense deduction of foreign corporations engaged in a trade or 
business within the United States. These final regulations conform the 
interest expense rules to recent U.S. Income Tax Treaty agreements and 
adopt other changes to improve compliance.

DATES: This correction is effective on November 5, 2009, and is 
applicable on September 28, 2009.

FOR FURTHER INFORMATION CONTACT: Anthony J. Marra, (202) 622-3870 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9465) that are the subject of this 
document are under sections 882 and 884 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9465) contain an error that 
may prove to be misleading and is in need of clarification.

Correction of Publication

    Accordingly, the publication of the final regulations (TD 9465), 
which were the subject of FR Doc. E9-22867, is corrected as follows:
    On page 49315, column 3, in the preamble, under the caption DATES, 
the language ``These final regulations are effective September 28, 
2009.'' is corrected to read ``Effective Date: These final regulations 
are effective on September 28, 2009.
    Applicability Date: These final regulations are applicable for 
taxable years ending on or after August 15, 2009. A taxpayer may choose 
to apply the temporary regulations (TD 9281, 71 FR 47443), rather than 
applying the final regulations, for any taxable year beginning on or 
after August 16, 2008, but before August 15, 2009.''.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, Procedure and Administration.
[FR Doc. E9-26272 Filed 11-4-09; 8:45 am]
BILLING CODE 4830-01-P