Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income; Correction, 43863 [E8-17269]

Download as PDF Federal Register / Vol. 73, No. 146 / Tuesday, July 29, 2008 / Rules and Regulations annuitized. The fair market value of such an annuity contract is permitted to be determined using the methodology provided in § 1.401(a)(9)–6, A–12, with the following modifications: (i) All front-end loads and other nonrecurring charges assessed in the twelve months immediately preceding the conversion must be added to the account value. (ii) Future distributions are not to be assumed in the determination of the actuarial present value of additional benefits. (iii) The exclusions provided under § 1.401(a)(9)–6, A–12(c)(1) and (c)(2), are not to be taken into account. (c) Effective/applicability date. The provisions of this paragraph A–14 are applicable to any conversion in which an annuity contract is distributed or treated as distributed from a traditional IRA on or after August 19, 2005. However, for annuity contracts distributed or treated as distributed from a traditional IRA on or before December 31, 2008, taxpayers may instead apply the valuation methods in § 1.408A–4T (as it appeared in the April 1, 2008, edition of 26 CFR part 1) and Revenue Procedure 2006–13 (2006–1 CB 315) (See § 601.601(d)(2)(ii)(b)). commerce under sections 367, 954, and 956 of the Internal Revenue Code. The regulations reflect statutory changes made by section 415 of the American Jobs Creation Act of 2004. In general, the regulations will affect the United States shareholders of controlled foreign corporations that derive income from the leasing of aircraft or vessels in foreign commerce and U.S. persons that transfer property subject to these leases to a foreign corporation. This correction is effective July 29, 2008, and is applicable on July 3, 2008. DATES: FOR FURTHER INFORMATION CONTACT: Concerning the temporary regulations under section 367, John H. Seibert at (202) 622–3860; concerning the temporary regulations under section 954 or 956, Paul J. Carlino at (202) 622–3840 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background The final and temporary regulations that are the subjects of this document are under sections 367, 954, and 956 of the Internal Revenue Code. Need for Correction Linda E. Stiff, Deputy Commissioner for Services and Enforcement. Approved: July 20, 2008. Eric Solomon, Assistant Secretary of the Treasury (Tax Policy). [FR Doc. E8–17271 Filed 7–28–08; 8:45 am] BILLING CODE 4830–01–P As published, final and temporary regulations (TD 9406) contain an error that may prove to be misleading and is in need of clarification. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Correction of Publication DEPARTMENT OF THE TREASURY Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment: I Internal Revenue Service 26 CFR Part 1 [TD 9406] PART 1—INCOME TAXES RIN 1545–BH03 I Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income; Correction Authority: 26 U.S.C. 7805 * * * Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. hsrobinson on PROD1PC76 with RULES AGENCY: I Par. 2. Section 1.954–2(c)(2) is amended by adding paragraph (vii) to read as follows: SUMMARY: This document contains a correction to final and temporary regulations (TD 9406) that was published in the Federal Register on Thursday, July 3, 2008 (73 FR 38113) addressing the treatment of certain income and assets related to the leasing of aircraft or vessels in foreign § 1.954–2 Foreign personal holding company income. VerDate Aug<31>2005 14:28 Jul 28, 2008 Jkt 214001 PO 00000 * * (c) * * * (2) * * * Frm 00019 * Fmt 4700 * Sfmt 4700 (vii) [Reserved]. For further guidance, see § 1.954–2T(c)(2)(vii). * * * * * LaNita Van Dyke, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. E8–17269 Filed 7–28–08; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9420] RIN 1545–BC22 Section 42 Utility Allowance Regulations Update Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. AGENCY: SUMMARY: This document contains final regulations that amend the utility allowances regulations concerning the low-income housing tax credit. The final regulations update the utility allowance regulations to provide new options for estimating tenant utility costs. The final regulations affect owners of low-income housing projects who claim the credit, the tenants in those low-income housing projects, and the State and local housing credit agencies that administer the credit. DATES: Effective Date: These regulations are effective July 29, 2008. Applicability Date: For dates of applicability see § 1.42–12(a)(4). FOR FURTHER INFORMATION CONTACT: David Selig (202) 622–3040 (not a tollfree number). SUPPLEMENTARY INFORMATION: Background Paragraph 1. The authority citation for part 1 continues to read, in part, as follows: * 43863 This document contains amendments to the Income Tax Regulations (26 CFR Part 1) relating to the low-income housing credit under section 42 of the Internal Revenue Code (Code). On June 19, 2007, the IRS and Treasury Department published in the Federal Register proposed regulations under section 42(g)(2)(B)(ii) (72 FR 33703). Written and electronic comments responding to the proposed regulations were received and a public hearing was held on the proposed regulations on October 9, 2007. After consideration of all the comments, the proposed regulations are adopted as amended by this Treasury decision. E:\FR\FM\29JYR1.SGM 29JYR1

Agencies

[Federal Register Volume 73, Number 146 (Tuesday, July 29, 2008)]
[Rules and Regulations]
[Page 43863]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-17269]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9406]
RIN 1545-BH03


Modifications to Subpart F Treatment of Aircraft and Vessel 
Leasing Income; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

-----------------------------------------------------------------------

SUMMARY: This document contains a correction to final and temporary 
regulations (TD 9406) that was published in the Federal Register on 
Thursday, July 3, 2008 (73 FR 38113) addressing the treatment of 
certain income and assets related to the leasing of aircraft or vessels 
in foreign commerce under sections 367, 954, and 956 of the Internal 
Revenue Code. The regulations reflect statutory changes made by section 
415 of the American Jobs Creation Act of 2004. In general, the 
regulations will affect the United States shareholders of controlled 
foreign corporations that derive income from the leasing of aircraft or 
vessels in foreign commerce and U.S. persons that transfer property 
subject to these leases to a foreign corporation.

DATES: This correction is effective July 29, 2008, and is applicable on 
July 3, 2008.

FOR FURTHER INFORMATION CONTACT: Concerning the temporary regulations 
under section 367, John H. Seibert at (202) 622-3860; concerning the 
temporary regulations under section 954 or 956, Paul J. Carlino at 
(202) 622-3840 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations that are the subjects of this 
document are under sections 367, 954, and 956 of the Internal Revenue 
Code.

Need for Correction

    As published, final and temporary regulations (TD 9406) contain an 
error that may prove to be misleading and is in need of clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

0
Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendment:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read, in 
part, as follows:

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

0
Par. 2. Section 1.954-2(c)(2) is amended by adding paragraph (vii) to 
read as follows:


Sec.  1.954-2  Foreign personal holding company income.

* * * * *
    (c) * * *
    (2) * * *
    (vii) [Reserved]. For further guidance, see Sec.  1.954-
2T(c)(2)(vii).
* * * * *

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E8-17269 Filed 7-28-08; 8:45 am]
BILLING CODE 4830-01-P

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