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Start Preamble
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Correction to final regulations.
SUMMARY:
This document contains corrections to final regulations (TD 8889) which were published in the Federal Register on Monday, July 3, 2000 (65 FR 40993). The final regulations relate to claims for certain income tax convention benefits.
DATES:
This correction is effective July 3, 2000.
Start Further InfoFOR FURTHER INFORMATION CONTACT:
Shawn R. Pringle (202) 622-3850 (not a toll-free number).
End Further Info End Preamble Start Supplemental InformationSUPPLEMENTARY INFORMATION:
Background
The final regulations that are subject to these corrections are under section 894 of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 8889) contains errors that may prove to be misleading and are in need of clarification.
Correction of Publication
Start Amendment PartAccordingly, the publication of final regulations (TD 8889),which was the subject of FR Doc. 00-16761, is corrected as follows:
End Amendment Part Start Amendment Part1. On page 40996, column 2, in the preamble under the paragraph heading “D. Treatment of Complex Trusts”, paragraph 2, line 13 from the bottom of the paragraph, the language “the hands of the interest holder are” is corrected to read “the hands of the interest holder are not”.
End Amendment Part Start Amendment Part2. One page 40997, column 1, in the preamble under the paragraph heading “Special Analyses”, paragraph 1, line 2, the language “treasury decision not a significant” is corrected to read “Treasury decision is not a significant”.
End Amendment Part[Corrected]3. On page 40997, column 1, correct the amendatory instruction for Par. 2. to read as follows:
End Amendment Part Start Amendment PartPar. 2. Section 1.894-1 is amended as follows:
End Amendment Part Start Amendment Part1. Paragraph (d) is redesignated as paragraph (e), and a new paragraph (d) is added.
End Amendment Part Start Amendment Part2. In newly designated paragraph (e), add a sentence at the end of the paragraph.
End Amendment Part Start Amendment PartThe additions read as follows:
End Amendment Part Start Amendment Part4. On page 40999, column 2, § 1.894-1(d)(5), paragraph (i) of Example 7., line 10, the language “legal personality of the arrangement, A is not” is corrected to read “legal personality in Country X of the arrangement, A is not”.
End Amendment Part Start Amendment Part5. On page 40999, column 2, § 1.894-1(d)(5), paragraph (i) of Example 7., lines 11 and 12, the language “liable to tax at the entity level of Country X and is not a resident within the meaning of” is corrected to read “liable to tax as a person at the entity level in Country X and is thus not a resident within the meaning of”.
End Amendment Part Start Amendment Part6. On page 40999, column 2, § 1.894-1(d)(5), paragraph (ii) of Example 7., line 9, the language “is not considered a resident of Country X” is corrected to read “is not considered a person in Country X and thus not a resident of Country X”.
End Amendment Part Start Amendment Part7. On page 40999, column 2, § 1.894-1(d)(5), paragraph (ii) of Example 7., line 12, the language “derive the income for purposes of the U.S.-” is corrected to read “derive the income as a resident of Country X for purposes of the U.S.-”.
End Amendment Part Start Amendment Part8. On page 41000, column 1, § 1.894-1(d)(5), paragraph (i) of Example 11., the last line of the paragraph, the language “subject to tax by Country X.” is corrected to read “taxed by Country X.”.
End Amendment Part Start Amendment Part9. On page 41000, column 2, § 1.894-1, after paragraph (d)(6), add a sentence at the end of paragraph (e) to read as follows:
End Amendment PartIncome affected by treaty.* * * * *(e) * * * See paragraph (d)(6) of this section for applicability dates for paragraph (d) of this section.
10. On page 41000, column 2, a new amendatory instruction Par. 3. is added to read as follows:
End Amendment Part Start Amendment PartPar. 3. Section 1.894-1T is removed.
End Amendment Part Start SignatureCynthia E. Grigsby,
Chief, Regulations Unit, Office of Special Counsel (Modernization & Strategic Planning).
[FR Doc. 00-31255 Filed 12-7-00; 8:45 am]
BILLING CODE 4830-01-U
Document Information
- Effective Date:
- 7/3/2000
- Published:
- 12/08/2000
- Department:
- Internal Revenue Service
- Entry Type:
- Rule
- Action:
- Correction to final regulations.
- Document Number:
- 00-31255
- Dates:
- This correction is effective July 3, 2000.
- Pages:
- 76932-76933 (2 pages)
- Docket Numbers:
- TD 8889
- RINs:
- 1545-AV10: Regulations Under Sections 871, 881, and 894 Regarding Payments to Partnerships, and Other Transparent Arrangements
- RIN Links:
- https://www.federalregister.gov/regulations/1545-AV10/regulations-under-sections-871-881-and-894-regarding-payments-to-partnerships-and-other-transparent-
- PDF File:
- 00-31255.pdf