[Federal Register Volume 74, Number 173 (Wednesday, September 9, 2009)]
[Rules and Regulations]
[Pages 46346-46347]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-21227]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9456]
RIN 1545-BI78, 1545-BI79, 1545-BI80


Treatment of Services Under Section 482; Allocation of Income and 
Deductions From Intangible Property; Apportionment of Stewardship 
Expense; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

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SUMMARY: This document contains corrections to final regulations (TD 
9456) that were published in the Federal Register on Tuesday, August 4, 
2009 (74 FR 38830) providing guidance regarding the treatment of 
controlled services transactions under section 482 and the allocation 
of income from intangible property, in particular with respect to 
contributions by a controlled party to the value of intangible property 
owned by another controlled party. These final regulations modify 
regulations under section 861 concerning stewardship expenses to be 
consistent with the changes made to the guidance under section 482.

DATES: This correction is effective on September 9, 2009, and is 
applicable on August 4, 2009.

FOR FURTHER INFORMATION CONTACT: Carol B. Tan or Gregory A. Spring, 
(202) 435-5265 for matters relating to section 482, or Richard L. 
Chewning, (202) 622-3850 for matters relating to stewardship expenses 
(not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations that are the subject of this document are 
under sections 482, 861, 6038, and 6662 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9456) contain errors that 
may prove to be misleading and are in need of clarification.

Correction of Publication

    Accordingly, the publication of the final regulations (TD 9456), 
which was the subject of FR Doc. E9-18326, is corrected as follows:
    1. On page 38830, column 1, in the title, the language ``Treatment 
of Services Under Section 482; Allocation of Income and Deductions From 
Intangible Property; Stewardship Expense'' is corrected to read 
``Treatment of Services Under Section 482; Allocation of Income and 
Deductions From Intangible Property; Apportionment of Stewardship 
Expense''.
    2. On page 38830, column 3, in the preamble, under the paragraph 
heading ``Background'', first paragraph of the column, third line from 
the bottom of the paragraph, the language ``years after December 31, 
2006) as the'' is corrected to read ``years beginning after December 
31, 2006) as the''.
    3. On page 38832, column 1, in the preamble, under the paragraph 
heading ``e. Business Judgment Rule'', first paragraph, eleventh line, 
the language ``one or more trades or business of the'' is corrected to 
read ``one or more trades or businesses of the''.
    4. On page 38833, column 1, in the preamble, under the paragraph 
heading ``g. Shared Services Arrangements'', second paragraph, fifth 
line, the language ``under an SSA to the service provider'' is 
corrected to read ``under a SSA to the service provider''.
    5. On page 38835, column 2, in the preamble, under the paragraph 
heading ``7. Controlled Services Transactions and Shareholder 
Activities--Treas. Reg. Sec.  1.482-9(l)'', second paragraph of the 
column, lines 1 and 2 from the bottom of the paragraph, the language 
``aggregate activity; rather than a component activity-by-activity 
basis.'' is corrected to read ``aggregate-activity basis; rather than a 
component activity-by-activity basis.''.
    6. On page 38835, column 3, in the preamble, under the paragraph 
heading ``b. Global Dealing Operations'', last line of the paragraph, 
the language ``of global

[[Page 46347]]

dealing regulations.'' is corrected to read ``of new global dealing 
regulations.''.
    7. On page 38837, column 1, in the first paragraph heading, the 
language ``D. Stewardship Expenses--Sec.  1.861-8'' is corrected to 
read ``D. Apportionment of Stewardship Expenses--Sec.  1.861-8''.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E9-21227 Filed 9-8-09; 8:45 am]
BILLING CODE 4830-01-P