Conduit Financing Arrangements; Correction

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document contains a correction to final regulations (TD 9562) that were published in the Federal Register on Friday, December 9, 2011 (76 FR 76895) providing guidance on conduit financing arrangements. The final regulations apply to multiple-party financing arrangements that are effected through disregarded entities, and are necessary in order to determine which of those arrangements should be recharacterized as a conduit financing arrangement.

DATES:

This correction is effective on April 16, 2012 and is applicable on December 9, 2011.

FOR FURTHER INFORMATION CONTACT:

Quyen P. Huynh, (202) 622-3880 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulation (TD 9562) that is the subject of this correction is under section 881 of the Internal Revenue Code.

Need for Correction

As published, TD 9562 contains errors that may prove to be misleading and is 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

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

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

Par. 2. For each entry in the table in the “Section” column, remove the language in the “Remove” column and add in its place the language in the “Add” column as set forth below: