81 FR 64061 - Country-by-Country Reporting; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 181 (September 19, 2016)

This document contains corrections to final regulations (TD 9773) that were published in the Federal Register on Thursday, June 30, 2016 (81 FR 42482). This document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.

[Federal Register Volume 81, Number 181 (Monday, September 19, 2016)]
[Rules and Regulations]
[Page 64061]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-22440]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9773]
RIN 1545-BM70


Country-by-Country Reporting; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final regulations (TD 
9773) that were published in the Federal Register on Thursday, June 30, 
2016 (81 FR 42482). This document contains final regulations that 
require annual country-by-country reporting by certain United States 
persons that are the ultimate parent entity of a multinational 
enterprise group.

DATES: This correction is effective September 19, 2016 and is 
applicable on or after June 30, 2016.

FOR FURTHER INFORMATION CONTACT: Melinda E. Harvey of the Office of 
Associate Chief Counsel (International) at (202) 317-6934 (not a toll-
free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9773) that are the subject of this 
correction are under section 1.6038-4 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9773) contain errors that 
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.

Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

     Authority: 26 U.S.C. 7805 * * *

0
Par. 2. Section 1.6038-4 is amended by revising paragraph (d)(3)(iv) to 
read as follows:


Sec.  1.6038-4  Information returns required of certain United States 
persons with respect to such person's U.S. multinational enterprise 
group.

* * * * *
    (d) * * *
    (3) * * *
    (iv) Income tax paid and accrued tax expense of permanent 
establishment. In the case of a constituent entity that is a permanent 
establishment, the amount of income tax paid and the amount of accrued 
tax expense referred to in paragraphs (d)(2)(iv) and (v) of this 
section should not include the income tax paid or tax expense accrued 
by the business entity of which the permanent establishment would be a 
part, but for the third sentence of paragraph (b)(2) of this section, 
in that business entity's tax jurisdiction of residence on the income 
derived by the permanent establishment.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-22440 Filed 9-16-16; 8:45 am]
 BILLING CODE 4830-01-P