Allocation and Sourcing of Income and Deductions Among Taxpayers Engaged in a Global Dealing Operation; Correction

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-208299-90]

RIN 1545-AP01

Allocation and Sourcing of Income and Deductions Among Taxpayers

Engaged in a Global Dealing Operation; Correction

AGENCY: Internal Revenue Service, Treasury.

ACTION: Correction to notice of proposed rulemaking.

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SUMMARY: This document contains corrections, including a change to the

date of the public hearing, to the notice of proposed rulemaking (REG-

208299-90) which was published in the Federal Register on Friday, March

6, 1998 (63 FR 11177). The notice of proposed rulemaking relates to the

allocation among controlled taxpayers and sourcing of income,

deductions, gains and losses from a global dealing operation; rules

applying these allocation and sourcing rules to foreign currency

transactions and to foreign corporations engaged in a U.S. trade or

business; and rules concerning the mark-to-market treatment resulting

from hedging activities of a global dealing operation.

DATES: The public hearing originally scheduled for July 9, 1998, has

been rescheduled for July 14, 1998.

ADDRESSES: The public hearing will be held in room 2615, Internal

Revenue Building, 1111 Constitution Avenue, NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT: Ginny Chung, (202) 622-3870 (not a

toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The notice of proposed rulemaking that is subject to these

corrections is under sections 482 and 864 of the Internal Revenue Code.

Need for Correction

As published, the notice of proposed rulemaking (REG-208299-90)

contain errors that may prove to be misleading and are in need of

clarification.

Correction of Publication

Accordingly, the publication of the notice of proposed rulemaking

(REG-208299-90) which is the subject of FR Doc. 98-5674 is corrected as

follows:

1. On page 11182, column 2, in the preamble under the heading ``K.

Source of Global Dealing Income'', in the second paragraph, line 5, the

language ``Sec. 1.863-3 which sources income from a'' is corrected to

read ``Sec. 1.863-3(h) which sources income from a''.

2. On page 11185, column 2, in the preamble under the heading

``Comments and Public Hearing'', in the second paragraph, line 2, the

language ``for July 9, 1998, at 10 a.m. in room 2615,'' is corrected to

read ``for July 14, 1998, at 10 a.m. in room 2615,''.

Cynthia E. Grigsby,

Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

[FR Doc. 98-10381 Filed 4-20-98; 8:45 am]

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