Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2009-09-28
Effective date
2009-09-28
Treasury docket
TD 9465
Abstract
This document contains final regulations under section 882(c) of the Internal Revenue Code (Code) concerning the determination of the interest expense deduction of foreign corporations engaged in a trade or business within the United States. These final regulations conform the interest expense rules to recent U.S. Income Tax Treaty agreements and adopt other changes to improve compliance.