IRS Corrects Typo in Final Regs on Hybrid Arrangements
T.D. 9896 (correction); 85 F.R. 47027
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Areas/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2020-29640
- Tax Analysts Electronic Citation2020 TNTI 149-212020 TNTG 149-242020 TNTF 149-24
Rules Regarding Certain Hybrid Arrangements; Correction
[4830-01-p]
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
RIN 1545-BO53
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final regulations; correction.
SUMMARY: This document contains corrections to final regulations Treasury Decision 9896 that were published in the Federal Register on Wednesday, April 8, 2020. The final regulations providing guidance regarding hybrid dividends and certain amounts paid or accrued pursuant to hybrid arrangements, which generally involve arrangements whereby U.S. and foreign tax law classify a transaction or entity differently for tax purposes.
DATES: This correction is effective on August 4, 2020.
FOR FURTHER INFORMATION CONTACT: Tracy Villecco at (202) 317–6933 or Tianlin (Laura) Shi at (202) 317–6936 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9896) that are the subject of this correction are issued under section 267A of the Code.
Need for Correction
As published April 8, 2020, the final regulations (TD 9896) contained an error that need to be corrected.
Correction of Publication
Accordingly, the final regulations (TD 9896), that are the subject of FR Doc. 2020-05924, are corrected as follows:
On page 19817, the first column, the fifth line of the fourth paragraph, the language "the use CFCs" is corrected to read "the use of CFCs".
Martin V. Franks
Chief, Publications and Regulations Branch
Legal Processing Division
Associate Chief Counsel
(Procedure and Administration)
[FR Doc. 2020-15940 Filed: 8/3/2020 8:45 am; Publication Date: 8/4/2020]
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Areas/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2020-29640
- Tax Analysts Electronic Citation2020 TNTI 149-212020 TNTG 149-242020 TNTF 149-24