Determination of Interest Expense Deduction of Foreign Corporations; CFR Correction

Federal Register: March 27, 2009 (Volume 74, Number 58)

Rules and Regulations

Page 13340

From the Federal Register Online via GPO Access [wais.access.gpo.gov]

DOCID:fr27mr09-6

DEPARTMENT OF THE TREASURY

Internal Revenue Service 26 CFR Part 1

Determination of Interest Expense Deduction of Foreign

Corporations

CFR Correction

In Title 26 of the Code of Federal Regulations, Part 1 (Sec. Sec. 1.851 to 1.907), revised as of April 1, 2008, on page 436, in Sec. 1.882-5, reinstate paragraph (d)(2)(ii)(B) to read as follows:

Sec. 1.882-5 Determination of interest deduction.

* * * * *

(d) * * *

(2) * * *

(ii) * * *

(B) Identified liabilities not properly reflected. A liability is not properly reflected on the books of the U.S. trade or business merely because a foreign corporation identifies the liability pursuant to Sec. 1.884-4(b)(1)(ii) and (b)(3).

* * * * *

FR Doc. E9-6944 Filed 3-26-09; 8:45 am

BILLING CODE 1505-01-D