Federal Register: November 5, 2009 (Volume 74, Number 213)
DOCID: fr05no09-7 FR Doc E9-26272
DEPARTMENT OF THE TREASURY
Internal Revenue Service
CFR Citation: 26 CFR Parts 1 and 602
RIN ID: RIN 1545-BF71
TD ID: [TD 9465]
NOTICE: RULES
DOCID: fr05no09-7
DOCUMENT ACTION: Correction to final regulations.
SUBJECT CATEGORY:
Determination of Interest Expense Deduction of Foreign Corporations; Correction
DATES: This correction is effective on November 5, 2009, and is applicable on September 28, 2009.
DOCUMENT 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.
SUMMARY:
Determination of Interest Expense Deduction of Foreign Corporations; Correction
SUPPLEMENTAL 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. E922867, 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. E926272 Filed 11409; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT
Anthony J. Marra, (202) 622-3870 (not a tollfree number).