Federal Register: March 19, 2009 (Volume 74, Number 52)
DOCID: fr19mr09-4 FR Doc E9-5950
DEPARTMENT OF THE TREASURY
Internal Revenue Service
CFR Citation: 26 CFR Part 1
RIN ID: RIN 1545-BI46
TD ID: [TD 9441]
NOTICE: RULES
DOCID: fr19mr09-4
ACTION: Section 482:
DOCUMENT ACTION: Correcting amendment.
SUBJECT CATEGORY:
Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
DATES: This correction is effective March 19, 2009, and is applicable on January 5, 2009.
DOCUMENT SUMMARY:
This document contains a correction to a correcting amendment for final and temporary regulations (TD 9441) that were published in the Federal Register on Thursday, March 5, 2009 (74 FR 9570) providing further guidance and clarification regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations. The temporary regulations affect domestic and foreign entities that enter into cost sharing arrangements described in the temporary regulations.
SUMMARY:
Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction,
SUPPLEMENTAL INFORMATION
Background
The final and temporary regulations that are the subject of this document are under sections 367 and 482 of the Internal Revenue Code. Need for Correction
As published, final and temporary regulations (TD 9441) contains 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
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:
PART 1INCOME TAXES
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.4820T is amended by removing and reserving the entry
of Sec. 1.4827T(h)(3)(vi)(B) and revising the entry of Sec. 1.482 7T(i)(6)(vi)(B) to read as follows:
Sec. 1.4820T Outline of regulations under section 482 (temporary). * * * * *
Sec. 1.4827T Methods to determine taxable income in connection with a cost sharing arrangement (temporary).
* * * * *
(i) * * *
(6) * * *
(vi) * * *
(B) Circumstances in which Periodic Trigger deemed not to occur. * * * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E95950 Filed 31809; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT
Kenneth P. Christman, (202) 435-5265 (not a tollfree number).