Treasury Department, Internal Revenue Service
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.
Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 9896] RIN 1545-BO53 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. 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: Effective date: This correction is effective on August 12, 2020. Applicability dates: For dates of applicability, see §§ 1.267A-7 and 1.1503(d). 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 sections 267A and 1503(d) of the Code. Need for Correction As published April 8, 2020 ( 85 FR 19802 ), the final regulation (TD 9896; FR Doc. 2020-05924 ) contained errors that need to be corrected. 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…
Other Federal Register documents from the same docket.
Citation: 85 FR 48651
