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Home » 2012 Issues » 77 FR (02/21/2012) » 2012-3855. Allocation and Apportionment of Interest Expense; Correction

  2012-3855. Allocation and Apportionment of Interest Expense; Correction  

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    AGENCY:

    Internal Revenue Service (IRS), Treasury.

    ACTION:

    Correcting amendment.

    SUMMARY:

    This document contains corrections to the final regulations (TD 9571), which were published in the Federal Register on January 17, 2012 (77 FR 2225) that provide guidance regarding the allocation and apportionment of interest expense.

    DATES:

    This correction is effective on February 21, 2012, and is applicable on January 17, 2012.

    Start Further Info

    FOR FURTHER INFORMATION CONTACT:

    Jeffrey L. Parry, (202) 622-3850 (not a toll-free call).

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    SUPPLEMENTARY INFORMATION:

    Background

    The temporary regulations (TD 9571) that are the subject of these corrections are under section 864 of the Internal Revenue Code.

    Need for Correction

    As published, the temporary regulations contain errors that may prove to be misleading and are in need of clarification.

    Start List of Subjects

    List of Subjects 26 CFR Part 1

    • Income taxes
    • Reporting and recordkeeping requirements
    End List of Subjects

    Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

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    PART 1—INCOME TAXES

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    Paragraph 1. The authority citation for part 1 continues to read in part as follows:

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    Authority: 26 U.S.C. 7805 * * *

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    [Corrected]
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    Par. 2. Section 1.861-9T is amended by revising paragraph (l) to read as follows:

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    Allocation and apportionment of interest expense (temporary).
    * * * * *

    (l) Expiration date. The applicability date of paragraphs (e)(2), (e)(3), and (h)(4) expires on January 13, 2015.

    [Corrected]
    Start Amendment Part

    Par. 3. Section 1.861-11T is amended by revising paragraph (i) to read as follows:

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    Special rules for allocating and apportioning interest expense of an affiliated group of corporations (temporary).
    * * * * *
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    (i) Expiration date. The applicability date of paragraph (d)(6)(ii) expires on January 13, 2015.

    Start Signature

    Robin R. Jones,

    Federal Register Liaison Officer, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration.

    End Signature End Supplemental Information

    [FR Doc. 2012-3855 Filed 2-17-12; 8:45 am]

    BILLING CODE 4830-01-P

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Document Information

Effective Date:
2/21/2012
Published:
02/21/2012
Department:
Internal Revenue Service
Entry Type:
Rule
Action:
Correcting amendment.
Document Number:
2012-3855
Dates:
This correction is effective on February 21, 2012, and is applicable on January 17, 2012.
Pages:
9844-9845 (2 pages)
Docket Numbers:
TD 9571
RINs:
1545-BJ84: Allocation and Apportionment of Interest Expense
RIN Links:
https://www.federalregister.gov/regulations/1545-BJ84/allocation-and-apportionment-of-interest-expense
Topics:
Income taxes, Reporting and recordkeeping requirements
PDF File:
2012-3855.pdf
CFR: (2)
26 CFR 1.861-9T
26 CFR 1.861-11T