Partner's Distributive Share; Correction, 33301 [E8-13251]

Download as PDF Federal Register / Vol. 73, No. 114 / Thursday, June 12, 2008 / Rules and Regulations sentence and adding, in its place, the word ‘‘will’’; I c. Paragraph (c)(3) is removed; and I d. Paragraphs (c)(4) and (c)(5) are redesignated as paragraphs (c)(3) and (c)(4), respectively. The revisions read as follows: § 10.16 Assembly abroad. * * * * * (b) Operations incidental to the assembly process. Operations incidental to the assembly process whether performed before, during, or after assembly, do not constitute further fabrication, and will not preclude the application of the exemption. The following are examples of operations which are incidental to the assembly process: * * * * * (3) Application of paint or preservative coating, including preservative metallic coating, lubricants, or protective encapsulation; * * * * * Approved: June 6, 2008. Jayson P. Ahern, Acting Commissioner, U.S. Customs and Border Protection. Timothy E. Skud, Deputy Assistant Secretary of the Treasury. [FR Doc. E8–13203 Filed 6–11–08; 8:45 am] BILLING CODE 9111–14–P provisions of the Internal Revenue Code on partnership allocations. DATES: This correction is effective June 12, 2008, and is applicable on May 19, 2008. FOR FURTHER INFORMATION CONTACT: Jonathan E. Cornwell and Kevin I. Babitz at (202) 622–3050 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the subject of this document are under section 704 of the Internal Revenue Code. Need for Correction As published, final regulations (TD 9398) 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 9398), which were the subject of FR Doc. E8–11176, is corrected as follows: On page 28701, column 2, in the preamble, under the paragraph heading ‘‘B. The Baseline for Comparison in § 1.704–1(b)(2)(iii)’’, line 2 from the bottom of the second paragraph, the language ‘‘and (2) and the conclusions reached by’’ is corrected to read ‘‘and (2) and the conclusions reached by’’. I 26 CFR Part 1 LaNita Van Dyke, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration). [FR Doc. E8–13251 Filed 6–11–08; 8:45 am] [TD 9398] BILLING CODE 4830–01–P DEPARTMENT OF THE TREASURY Internal Revenue Service RIN 1545–BD70 DEPARTMENT OF THE TREASURY Partner’s Distributive Share; Correction Internal Revenue Service Internal Revenue Service (IRS), Treasury. ACTION: Final regulations; correction. rwilkins on PROD1PC63 with RULES AGENCY: SUMMARY: This document contains a correction to final regulations (TD 9398) that were published in the Federal Register on Monday, May 19, 2008 (73 FR 28699) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) where partners are look-through entities or members of a consolidated group. The final regulations clarify the application of section 704(b) to partnerships the interests of which are owned by lookthrough entities and members of consolidated groups and, through an example, reiterate the effect of other VerDate Aug<31>2005 16:29 Jun 11, 2008 Jkt 214001 26 CFR Part 1 [TD 9398] RIN 1545–BD70 Partner’s Distributive Share; Correction Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. AGENCY: SUMMARY: This document contains corrections to final regulations (TD 9398) that were published in the Federal Register on Monday, May 19, 2008 (73 FR 28699) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) where PO 00000 Frm 00011 Fmt 4700 Sfmt 4700 33301 partners are look-through entities or members of a consolidated group. The final regulations clarify the application of section 704(b) to partnerships the interests of which are owned by lookthrough entities and members of consolidated groups and, through an example, reiterate the effect of other provisions of the Internal Revenue Code on partnership allocations. DATES: This correction is effective June 12, 2008, and is applicable on May 19, 2008. FOR FURTHER INFORMATION CONTACT: Jonathan E. Cornwell and Kevin I. Babitz at (202) 622–3050 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the subject of this document are under section 704 of the Internal Revenue Code. Need for Correction As published, final regulations (TD 9398) contain errors that may prove to be misleading and are in need of clarification. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Correction of Publication Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments: I PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read, in part, as follows: I Authority: 26 U.S.C. 7805 * * * I Par. 2. Section 1.704–1 is amended as follows: 1. In paragraph (b)(2)(iii)(d)(3), the last sentence, the language ‘‘In the case of a controlled foreign corporation that is a look-through entity, the tax attributes to be taken into account are those of any person that is a United States shareholder (as defined in paragraph (b)(2)(iii)(d)(5) of this section) of the controlled foreign corporation, or, if the United States shareholder is a look-through entity, a United States person that owns an interest in such shareholder directly or indirectly through one or more look-through entities.’’ is removed and the language ‘‘In the case of a controlled foreign corporation that is a look-through entity, the tax attributes to be taken into account are those of any person that is a United States shareholder (as defined E:\FR\FM\12JNR1.SGM 12JNR1

Agencies

[Federal Register Volume 73, Number 114 (Thursday, June 12, 2008)]
[Rules and Regulations]
[Page 33301]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-13251]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9398]
RIN 1545-BD70


Partner's Distributive Share; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations; correction.

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SUMMARY: This document contains a correction to final regulations (TD 
9398) that were published in the Federal Register on Monday, May 19, 
2008 (73 FR 28699) providing rules for testing whether the economic 
effect of an allocation is substantial within the meaning of section 
704(b) where partners are look-through entities or members of a 
consolidated group. The final regulations clarify the application of 
section 704(b) to partnerships the interests of which are owned by 
look-through entities and members of consolidated groups and, through 
an example, reiterate the effect of other provisions of the Internal 
Revenue Code on partnership allocations.

DATES: This correction is effective June 12, 2008, and is applicable on 
May 19, 2008.

FOR FURTHER INFORMATION CONTACT: Jonathan E. Cornwell and Kevin I. 
Babitz at (202) 622-3050 (not a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations that are the subject of this document are 
under section 704 of the Internal Revenue Code.

Need for Correction

    As published, final regulations (TD 9398) contain an error that may 
prove to be misleading and is in need of clarification.

Correction of Publication

0
Accordingly, the publication of the final regulations (TD 9398), which 
were the subject of FR Doc. E8-11176, is corrected as follows:
    On page 28701, column 2, in the preamble, under the paragraph 
heading ``B. The Baseline for Comparison in Sec.  1.704-1(b)(2)(iii)'', 
line 2 from the bottom of the second paragraph, the language ``and (2) 
and the conclusions reached by'' is corrected to read ``and (2) and the 
conclusions reached by''.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
 [FR Doc. E8-13251 Filed 6-11-08; 8:45 am]
BILLING CODE 4830-01-P