Product Valuation, 3606-3607 [2012-1572]
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3606
Federal Register / Vol. 77, No. 16 / Wednesday, January 25, 2012 / Rules and Regulations
3. On page 80086, column three, in
the preamble, paragraph d. introductory
text, the language ‘‘Contractual CWI
Provisions—§ 1.482–1(d)(3)(ii)(C),
Examples 3 through 7’’ is corrected to
read ‘‘Contractual CWI Provisions—
§ 1.482–7(h)(2)(iii)(C), Examples 3
through 7.’’.
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 * * *
PART 1—[CORRECTED]
Guy R. Traynor,
Federal Register Liaison, Legal Processing
Division, Publication and Regulations
Branch, Procedure and Administration.
■
[FR Doc. 2012–894 Filed 1–24–12; 8:45 am]
§ 1.482–1 Allocation of income and
deductions among taxpayers.
Par. 2. Section 1.482–1 is amended by
revising the first and second sentences
of paragraph (b)(2)(i) to read as follows:
BILLING CODE 4830–01–P
*
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9568]
RIN 1545–BI47
Section 482; Methods To Determine
Taxable Income in Connection With a
Cost Sharing Arrangement; Correction
Internal Revenue Service (IRS).
Correcting amendment.
AGENCY:
ACTION:
This document contains
corrections to final regulations (TD
9568), which were published in the
Federal Register on Thursday,
December 22, 2011 (76 FR 80082),
Relating to section 482 and methods to
determine taxable income in connection
with a cost sharing arrangement.
DATES: Effective January 25, 2012, and
applicable beginning December 22,
2011.
SUMMARY:
FOR FURTHER INFORMATION CONTACT:
Joseph L. Tobin at (202) 435–5265 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the
subject of these corrections are under
section 482 of the Internal Revenue
Code.
Need for Correction
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As published, final regulations (TD
9568), contains errors which 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.
Accordingly, 26 CFR Parts 1 and 301
are corrected by making the following
correcting amendments:
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21:03 Jan 24, 2012
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*
*
*
*
(b) * * *
(2) * * *
(i) Methods. Sections 1.482–2 through
1.482–7 and 1.482–9 provide specific
methods to be used to evaluate whether
transactions between or among members
of the controlled group satisfy the arm’s
length standard, and if they do not, to
determine the arm’s length result. This
section provides general principles
applicable in determining arm’s length
results of such controlled transactions,
but do not provide methods, for which
reference must be made to those other
sections in accordance with paragraphs
(b)(2)(ii) and (iii) of this section. * * *
*
*
*
*
*
Par. 3. Section 1.482–7 is amended
by:
■ 1. Revising the fourth sentence of
paragraph (c)(3).
■ 2. Revising the fifth sentence of
paragraph (g)(2)(v)(C), Example,
paragraph (i).
■ 3. Revising the first sentence of
paragraph (g)(2)(v)(C), Example,
paragraph (ii).
■ 4. Revising paragraph (k)(2)(ii)(3).
The revisions read as follows:
§ 1.482–7 Methods to determine taxable
income in connection with a cost sharing
arrangement.
*
*
*
*
*
(c) * * *
(3) * * * If the conduct is consistent
with different, economically equivalent
types of transactions then the controlled
participants may designate the PCT as
being any of such types of transactions.
* * *
*
*
*
*
*
(g) * * *
(2) * * *
(v) * * *
(C) * * *
Example. (i) * * * Specifically, the
Commissioner compares P’s anticipated posttax discounted present value of the financial
projections under the CSA (taking into
account S’s PCT payment of 5% of its sale
of product Y) with P’s anticipated post-tax
discounted present value of the financial
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projections under a reasonably available
licensing alternative that consists of
developing intangible X on its own and then
licensing X to S or to an uncontrolled party
similar to S.
*
*
*
*
*
(ii) The Commissioner determines
that, as between the two scenarios, all
of the components of P’s anticipated
financial flows are identical, except for
the CST and PCT Payments under the
CSA, compared to the licensing
payments under the licensing
alternative. * * *
*
*
*
*
*
(3) * * *
(viii) * * *
Example 3. * * * FS determines that the
discount rate that would be applied to
determine the present value of income and
costs attributable to its participation in the
licensing alternative would be 12.5% as
compared to the 15% discount rate that
would be applicable in determining the
present value of the net income attributable
to its participation in the CSA (reflecting the
increased risk borne by FS in bearing a share
of the R & D costs in the cost sharing
alternative). * * *
*
*
*
*
*
(k) * * *
(2) * * *
(ii) * * *
(3) Any further development of
intangibles already developed under the
CSA or of specified applications of such
intangible which has been removed
from the IDA (see paragraphs (d)(1)(ii)
and (j)(1)(i) of this section for the
definitions of reasonably anticipated
cost shared intangible and cost shared
intangible) and the steps (including any
accounting classifications and
allocations) taken to implement such
removal;
*
*
*
*
*
Guy R. Traynor,
Federal Register Liaison, Legal Processing
Division, Publication & Regulation Branch
(Procedure and Administration).
[FR Doc. 2012–895 Filed 1–24–12; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE INTERIOR
Office of Natural Resources Revenue
30 CFR Part 1206
Product Valuation
CFR Correction
In Title 30 of the Code of Federal
Regulations, Part 700 to End, revised as
of July 1, 2011, ‘‘ONNR’’ is corrected to
read ‘‘ONRR’’, as set forth in the
following table:
■
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Federal Register / Vol. 77, No. 16 / Wednesday, January 25, 2012 / Rules and Regulations
3607
§§ 1206.52, 1206.53, 1206.54, 1206.56,
1206.57 [Corrected]
Section
Page
§ 1206.52 .......................................................
§ 1206.53
§ 1206.54
§ 1206.56
§ 1206.57
.......................................................
.......................................................
.......................................................
.......................................................
739
740
741
741
742
742
743
744
745
746
BILLING CODE 1505–01–D
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 117
[Docket No. USCG–2012–0026]
Drawbridge Operation Regulation;
Willamette River, Portland, OR
Coast Guard, DHS.
ACTION: Notice of temporary deviation
from regulations.
AGENCY:
The Commander, Thirteenth
Coast Guard District, has issued a
temporary deviation from the regulation
governing the operation of the
Burlington Northern Santa Fe Railway
Bridge, also known as the St Johns RR
Bridge, across the Willamette River,
mile 6.9, at Portland, OR. The deviation
is necessary to facilitate track
maintenance involving welding on the
movable section of the bridge. This
deviation allows the bridge to remain in
the closed position during maintenance
activities.
DATES: This deviation is effective from
9 a.m. on January 30, 2012 through 3
p.m. February 1, 2012.
ADDRESSES: Documents mentioned in
this preamble as being available in the
docket are part of docket USCG–2012–
0026 and are available online by going
to https://www.regulations.gov, inserting
USCG–2012–0026 in the ‘‘Keyword’’
box and then clicking ‘‘Search’’. They
are also available for inspection or
copying at the Docket Management
Facility (M–30), U.S. Department of
Transportation, West Building Ground
Floor, Room W12–140, 1200 New Jersey
Avenue SE., Washington, DC 20590,
between 9 a.m. and 5 p.m., Monday
through Friday, except Federal holidays.
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(c) introductory text, (c)(2) introductory text, (c)(2)(i), (c)(2)(ii),
(e)(3) two times, (e)(4) introductory text, (e)(5) two times.
(c) introductory text, (d).
(a)
(a), (b)(2) two times, (d).
(a)(1)(i) two times, (a)(1)(ii) two times, (a)(1)(iii) once.
(a)(1)(iii) three times, (a)(2)(i), (a)(2)(ii) two times, (a)(3) five times, (a)(5) two times,
(b)(1) four times,
(b)(2)(iv) introductory text, (b)(2)(iv)(A), (b)(2)(iv)(B), (b)(3)(i), (b)(3)(ii) two times,
(b)(4) five times, (b)(5) introductory text four times, (b)(5)(i), (c)(1)(iii), (c)(1)(iv) two
times, (c)(1)(v),
(c)(2)(iii) two times, (c)(2)(v), (c)(2)(vi) two times, (c)(2)(vii), (c)(4).
If
you have questions on this rule, call or
email the Bridge Administrator, Coast
Guard Thirteenth District; telephone
(206) 220–7282 email
randall.d.overton@uscg.mil. If you have
questions on viewing the docket, call
Renee V. Wright, Program Manager,
Docket Operations, telephone (202)
366–9826.
SUPPLEMENTARY INFORMATION: Burlington
Northern Santa Fe (BNSF) Railway has
requested to not open the BNSF
Railroad Lift Bridge for vessels to
facilitate track maintenance. The bridge,
also known as the St Johns RR Bridge,
crosses the Willamette River at mile 6.9
and provides 54 feet of vertical
clearance above Columbia River Datum
0.0, while in the closed position.
Vessels which do not require a bridge
opening may continue to transit beneath
the bridge during this closure period.
Under normal operations this bridge
opens on signal as required by 33 CFR
117.5. The deviation period is from 9
a.m. on January 30, 2012 through 3 p.m.
February 1, 2012. This deviation allows
the lift span of the BNSF Railway Bridge
across the Willamette River, mile 6.9, to
remain in the closed position and need
not open for maritime traffic from 9 a.m.
through 3 p.m. daily from January 30,
2012 through February 1, 2012. The
bridge shall operate in accordance to 33
CFR 117.5 at all other times. Waterway
usage on this stretch of the Willamette
River includes vessels ranging from
commercial tug and barge to small
pleasure craft. Mariners have been
notified and will be kept informed of
the bridge’s operational status via the
Coast Guard Notice to Mariners
publication and Broadcast Notice to
Mariners as appropriate. Due to the
nature of work being performed the
draw span will be unable to open for
maritime traffic during this maintenance
period.
In accordance with 33 CFR 117.35(e),
the drawbridge must return to its regular
FOR FURTHER INFORMATION CONTACT:
[FR Doc. 2012–1572 Filed 1–24–12; 8:45 am]
SUMMARY:
Paragraph
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operating schedule immediately at the
end of the designated time period. This
deviation from the operating regulations
is authorized under 33 CFR 117.35.
Dated: January 11, 2012.
Randall D. Overton,
Bridge Administrator.
[FR Doc. 2012–1439 Filed 1–24–12; 8:45 am]
BILLING CODE 9110–04–P
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 117
[Docket Number USCG–2011–1177]
Drawbridge Operation Regulation;
Upper Mississippi River, Rock Island,
IL
Coast Guard, DHS.
Notice of temporary deviation
from regulations.
AGENCY:
ACTION:
The Commander, Eighth
Coast Guard District, has issued a
temporary deviation from the regulation
governing the operation of the Rock
Island Railroad and Highway
Drawbridge across the Upper
Mississippi River, mile 482.9, at Rock
Island, Illinois. The deviation is
necessary to allow the Quad Cities Heart
Walk to cross the bridge. This deviation
allows the bridge to be maintained in
the closed-to-navigation position for two
hours.
DATES: This deviation is effective from
9 a.m. to 11 a.m. on May 19, 2012.
ADDRESSES: Documents mentioned in
this preamble as being available in the
docket are part of docket USCG–2011–
1177 and are available online by going
to https://www.regulations.gov, inserting
USCG–2011–1177 in the ‘‘Keyword’’
box and then clicking ‘‘Search’’. They
are also available for inspection or
SUMMARY:
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]]>Agencies
[Federal Register Volume 77, Number 16 (Wednesday, January 25, 2012)]
[Rules and Regulations]
[Pages 3606-3607]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-1572]
=======================================================================
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DEPARTMENT OF THE INTERIOR
Office of Natural Resources Revenue
30 CFR Part 1206
Product Valuation
CFR Correction
0
In Title 30 of the Code of Federal Regulations, Part 700 to End,
revised as of July 1, 2011, ``ONNR'' is corrected to read ``ONRR'', as
set forth in the following table:
[[Page 3607]]
Sec. Sec. 1206.52, 1206.53, 1206.54, 1206.56, 1206.57 [Corrected]
------------------------------------------------------------------------
Section Page Paragraph
------------------------------------------------------------------------
Sec. 1206.52..................... 739 (c) introductory text,
(c)(2) introductory text,
(c)(2)(i), (c)(2)(ii),
740 (e)(3) two times, (e)(4)
introductory text, (e)(5)
two times.
Sec. 1206.53..................... 741 (c) introductory text,
(d).
Sec. 1206.54..................... 741 (a)
Sec. 1206.56..................... 742 (a), (b)(2) two times,
(d).
Sec. 1206.57..................... 742 (a)(1)(i) two times,
(a)(1)(ii) two times,
(a)(1)(iii) once.
743 (a)(1)(iii) three times,
(a)(2)(i), (a)(2)(ii) two
times, (a)(3) five times,
(a)(5) two times, (b)(1)
four times,
744 (b)(2)(iv) introductory
text, (b)(2)(iv)(A),
(b)(2)(iv)(B), (b)(3)(i),
(b)(3)(ii) two times,
745 (b)(4) five times, (b)(5)
introductory text four
times, (b)(5)(i),
(c)(1)(iii), (c)(1)(iv)
two times, (c)(1)(v),
746 (c)(2)(iii) two times,
(c)(2)(v), (c)(2)(vi) two
times, (c)(2)(vii),
(c)(4).
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[FR Doc. 2012-1572 Filed 1-24-12; 8:45 am]
BILLING CODE 1505-01-D
