TD 8434 (Correction)

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Treasury Decisions

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Rules and Regulations

DEPARTMENT OF THE TREASURY

Internal Revenue Service (IRS)

26 CFR Part 1

58 FR 13412; RIN 1545-AM16

Treatment of Dual Consolidated Losses; Correction

T.D. 8434

DATE: March 11, 1993

ACTION: Correction to final regulations.

SUMMARY: This document contains a correction to the final regulations (T.D. 8434), which were published in the Federal Register for Wednesday, September 9, 1992 (57 FR 41079). The final regulations provide that a dual consolidated loss of a dual resident corporation may not be used to offset the taxable income of any domestic corporate affiliate.

EFFECTIVE DATE: October 1, 1992.

FOR FURTHER INFORMATION CONTACT: Sim Seo (202) 622-3840 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of this correction implements section 1503(d) of the Internal Revenue Code of 1986. Section 1503(d) was added to the Code by section 1249 of the Tax Reform Act of 1986 (Pub L. 99-514) and was amended by section 1012(u) of the Technical and Miscellaneous Revenue Act of 1988 ( Pub. L. 100-647).

Need for Correction

As published, T.D. 8434 contains an error which may prove to be misleading and is in need of clarification.

Correction of Publication

Accordingly, the publication of the final regulations (T.D. 8434), which was the subject of FR Doc. 92-21539, is corrected as follows:

On page 41087, column 1, § 1.1503-2(d)(2)(ii), third line from the bottom of the column, the language "limitations of § 1.502-21(c), as if the" is corrected to read "limitations of § 1.1502-21(c), as if the".

Dale D. Goode,

Federal Register Liaison Officer, Assistant Chief Counsel (Corporate).

[FR Doc. 93-5520 Filed 3-10-93; 8:45 am]

BILLING CODE 4830-01-M

11052B

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