Federal Register: September 9, 2009 (Volume 74, Number 173)
DOCID: fr09se09-18 FR Doc E9-21227
DEPARTMENT OF THE TREASURY
Internal Revenue Service
CFR Citation: 26 CFR Part 1
RIN ID: RIN 1545-BI78, 1545-BI79, 1545-BI80
TD ID: [TD 9456]
NOTICE: RULES
DOCID: fr09se09-18
DOCUMENT ACTION: Correction to final regulations.
SUBJECT CATEGORY:
Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Apportionment of Stewardship Expense; Correction
DATES: This correction is effective on September 9, 2009, and is applicable on August 4, 2009.
DOCUMENT SUMMARY:
This document contains corrections to final regulations (TD 9456) that were published in the Federal Register on Tuesday, August 4, 2009 (74 FR 38830) providing guidance regarding the treatment of controlled services transactions under section 482 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. These final regulations modify regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the guidance under section 482.
SUMMARY:
Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property, etc.; Correction
SUPPLEMENTAL INFORMATION
Background
The final regulations that are the subject of this document are under sections 482, 861, 6038, and 6662 of the Internal Revenue Code. Need for Correction
As published, the final regulations (TD 9456) contain errors that may prove to be misleading and are in need of clarification. Correction of Publication
Accordingly, the publication of the final regulations (TD 9456), which was the subject of FR Doc. E918326, is corrected as follows:
1. On page 38830, column 1, in the title, the language ``Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Stewardship Expense'' is corrected to read ``Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Apportionment of Stewardship Expense''.
2. On page 38830, column 3, in the preamble, under the paragraph heading ``Background'', first paragraph of the column, third line from the bottom of the paragraph, the language ``years after December 31, 2006) as the'' is corrected to read ``years beginning after December 31, 2006) as the''.
3. On page 38832, column 1, in the preamble, under the paragraph heading ``e. Business Judgment Rule'', first paragraph, eleventh line, the language ``one or more trades or business of the'' is corrected to read ``one or more trades or businesses of the''.
4. On page 38833, column 1, in the preamble, under the paragraph heading ``g. Shared Services Arrangements'', second paragraph, fifth line, the language ``under an SSA to the service provider'' is corrected to read ``under a SSA to the service provider''.
5. On page 38835, column 2, in the preamble, under the paragraph heading ``7. Controlled Services Transactions and Shareholder ActivitiesTreas. Reg. Sec. 1.4829(l)'', second paragraph of the column, lines 1 and 2 from the bottom of the paragraph, the language ``aggregate activity; rather than a component activitybyactivity basis.'' is corrected to read ``aggregateactivity basis; rather than a component activitybyactivity basis.''.
6. On page 38835, column 3, in the preamble, under the paragraph
heading ``b. Global Dealing Operations'', last line of the paragraph, the language ``of global
[[Page 46347]]
dealing regulations.'' is corrected to read ``of new global dealing regulations.''.
7. On page 38837, column 1, in the first paragraph heading, the
language ``D. Stewardship ExpensesSec. 1.8618'' is corrected to
read ``D. Apportionment of Stewardship ExpensesSec. 1.8618''. LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E921227 Filed 9809; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT
Carol B. Tan or Gregory A. Spring, (202) 4355265 for matters relating to section 482, or Richard L. Chewning, (202) 6223850 for matters relating to stewardship expenses (not tollfree numbers).