Determination of Interest Expense Deduction of Foreign Corporations, 13340 [E9-6944]
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Federal Register / Vol. 74, No. 58 / Friday, March 27, 2009 / Rules and Regulations
eligible immigration status under HUD’s
noncitizens regulations, nor do they
interfere with existing requirements
relative to proration of assistance or
screening for such families, or authorize
their eviction or denial of admission on
the basis of the new requirements
pertaining to obtaining social security
numbers.
The February 11, 2009, notice
solicited comments specifically on a
delayed effective date, but also generally
on the January 27, 2009 final rule. HUD
received approximately 50 comments in
response to the February 11, 2009,
notice. The majority of comments were
supportive of a delayed effective date.
The majority of the commenters also
raised additional questions and
comments about various aspects of the
January 27, 2009, final rule.
II. This Final Rule
sroberts on PROD1PC70 with RULES
Through this final rule, HUD delays
the effective date of the January 27,
2009, final rule until September 30,
2009. A delay until September 30, 2009
will provide HUD with additional time
to review the public comments received
in response to the February 11, 2009,
notice, respond to those comments in a
subsequent publication, and consider
whether additional regulations or
changes to the regulations in the January
27, 2009, final rule are necessary or
appropriate. Since September 30, 2009,
is the date in the January 27, 2009, final
rule for multifamily housing owners and
management agents to implement the
use of EIV, the Department has
determined not to provide additional
delay in implementation in the use of
EIV for multifamily housing owners and
management agents as provided in the
January 27, 2009, final rule. The
implementation date for public housing
agencies, multifamily housing owners,
and management agents will now all be
the same as the new effective date,
September 30, 2009. Should HUD
determine that additional rulemaking is
necessary or appropriate, HUD will
provide the public with the opportunity
to comment on any proposed changes to
the regulations in the January 27, 2009,
final rule.
Dated: March 24, 2009.
Paula O. Blunt,
General Deputy Assistant Secretary for Public
and Indian Housing.
[FR Doc. E9–6942 Filed 3–26–09; 8:45 am]
BILLING CODE 4210–67–P
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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 (§§ 1.851 to 1.907),
revised as of April 1, 2008, on page 436,
in § 1.882–5, reinstate paragraph
(d)(2)(ii)(B) to read as follows:
§ 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 § 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
Background
The final regulations that are the
subject of this document are under
section 367(a) of the Internal Revenue
Code.
Need for Correction
The final regulations (TD 9446) that
were published in the Federal Register
on February 11, 2009 (74 FR 6952),
inadvertently removed Treas. Reg.
§ 1.367(a)–3T in its entirety rather than
removing § 1.367(a)–3T(e), (f)(1), (f)(2),
and the second sentence of § 1.367(a)–
3T(f)(3). This document correctly adds
the text of § 1.367(a)–3T back into the
Code of Federal Regulations.
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:
■
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
Authority: 26 U.S.C. 7805 * * *
DEPARTMENT OF THE TREASURY
Internal Revenue Service
§ 1.367(a)–3T Treatment of transfers of
stock or securities to foreign corporations
(temporary).
26 CFR Part 1
[TD 9446]
RIN 1545–BGO9
Gain Recognition Agreements With
Respect to Certain Transfers of Stock
or Securities by United States Persons
to Foreign Corporations; Correction
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
SUMMARY: This document contains
corrections to final regulations (TD
9446) that were published in the
Federal Register on Wednesday,
February 11, 2009 concerning gain
recognition agreements filed by United
States persons with respect to transfers
of stock or securities to foreign
corporations.
DATES: This correction is effective on
March 27, 2009, and is applicable on
March 13, 2009.
FOR FURTHER INFORMATION CONTACT: S.
James Hawes, (202) 622–3860 (not a tollfree number).
SUPPLEMENTARY INFORMATION:
PO 00000
Frm 00028
Fmt 4700
Par. 2. Section 1.367(a)–3T is added
to read as follows:
■
Sfmt 4700
(a) through (b)(2)(i)(B) [Reserved]. For
further guidance, see § 1.367(a)–3(a)
through (b)(2)(i)(B).
(b)(2)(i)(C) If in connection with a
transaction described in § 1.367(b)–14T,
one or more U.S. persons transfer stock
of T, as defined in § 1.358–6(b)(1)(iii), to
a corporation in a transfer described in
section 367(a), and the amount of gain
in the T stock that would otherwise be
recognized under section 367(a) is less
than the deemed distribution that would
result from the adjustments made under
§ 1.367(b)–14T and that would be
treated as a dividend under section
301(c)(1), then section 367(b), and not
section 367(a), shall apply to such
transaction. This paragraph (b)(2)(i)(C)
applies to transfers occurring on or after
May 23, 2008.
(b)(2)(ii) through (f) [Reserved]. For
further guidance, see § 1.367(a)–
3(b)(2)(ii) through (f).
(g) Effective/applicability date.
Paragraph (b)(2)(i)(C) of this section
applies to transfers occurring on or after
May 23, 2008.
(h) Expiration date. The applicability
of paragraph (b)(2)(i)(C) of this section
expires on May 23, 2011.
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[Federal Register Volume 74, Number 58 (Friday, March 27, 2009)]
[Rules and Regulations]
[Page 13340]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-6944]
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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
