[Federal Register Volume 75, Number 173 (Wednesday, September 8, 2010)]
[Proposed Rules]
[Pages 54541-54542]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-22239]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 31

[REG-146893-02, REG-115037-00]
RIN 1545-BJ32


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

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking.

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SUMMARY: This document withdraws proposed regulations published in the 
Federal Register on September 10, 2003 (68 FR 53448), related to 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 that 
is owned by another controlled party. The IRS and Treasury Department 
are withdrawing those proposed regulations because they have been 
superseded.

FOR FURTHER INFORMATION CONTACT: Gregory A. Spring (202) 435-5265 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    On September 10, 2003, the Treasury Department and the IRS 
published in the Federal Register (68 FR 53448, REG-146893-02 and REG-
115037-00) proposed regulations relating to the treatment of controlled 
services transactions and the allocation of income from intangible 
property, in particular with respect to contributions by a controlled 
party to the value of intangible property owned by another controlled 
party. On August 4, 2006, the Treasury Department and the IRS published 
in the Federal Register (71 FR 44466, TD 9278, REG-146893-02, REG-
115037-00, and REG-138603-03) temporary regulations relating to the 
treatment of controlled services transactions, the allocation of income 
from intangible property, and stewardship expenses under Treas. Reg. 
Sec.  1.861-8(e)(4). A notice of proposed rulemaking cross-referencing 
the temporary regulations was published in the Federal Register on the 
same day (71 FR 44247). Written comments responding to the notice of 
proposed rulemaking were received, and a public hearing was held on 
October 27, 2006. That notice of proposed rulemaking superseded the 
proposed regulations published in the Federal Register on September 10, 
2003.
    On August 4, 2009, the Treasury Department and the IRS published in 
the Federal Register (74 FR 38830, TD 9456) final regulations that are 
generally consistent with the proposed regulations that were published 
on August 4, 2006, in the Federal Register (71 FR 44247), and removed 
the corresponding temporary regulations.

List of Subjects

26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

26 CFR Part 31

    Employment taxes, Income taxes, Penalties, Pensions, Railroad 
retirement, Reporting and recordkeeping

[[Page 54542]]

requirements, Social Security, Unemployment compensation.

Withdrawal of a Notice of Proposed Rulemaking

    Accordingly, under the authority of 26 U.S.C. 7805, the notice of 
proposed rulemaking (REG-146893-02 and REG-115037-00) published in the 
Federal Register on September 10, 2003 (68 FR 53448) is withdrawn.

Steven T. Miller,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2010-22239 Filed 9-7-10; 8:45 am]
BILLING CODE 4830-01-P