Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; Stewardship Expense; Correction
other · IRS · Rule · Published 2006-12-22 · Effective 2007-01-01 · 71 FR 76913
Document
Document number
E6-21907
Federal Register citation
71 FR 76913
CFR reference
26 CFR 1
Type
Rule
Action
Correction to final and temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2006-12-22
Effective date
2007-01-01
Treasury docket
TD 9278
Abstract
This document contains corrections to final and temporary regulations (TD 9278) that was published in the Federal Register on Friday, August 4, 2006 (71 FR 44466) regarding the treatment of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party. This document also contains corrections to final and temporary regulations that modify the regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482.