Proposed Amendments to the regulations on the
Determination of Interest Expense Deduction of
Foreign Corporations & Branch Profits Tax

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [INTL-0054-95] RIN 1545-AT96

TITLE: Proposed amendments to the regulations on the determination of interest expense deduction of foreign corporations and branch profits tax

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains proposed Income Tax Regulations relating to the determination of the interest expense deduction of foreign corporations under section 882 and the branch profits tax under section 884 of the Internal Revenue Code of 1986. These proposed regulations are necessary to provide guidance that coordinates with guidance provided in final regulations under sections 882 and 884 published elsewhere in this issue of the Federal Register. These regulations will affect foreign corporations engaged in a U.S. trade or business. This document also provides notice of a public hearing on these proposed regulations.

DATES: Written comments must be received by June 6, 1996. Outlines of topics to be discussed at the public hearing scheduled for Thursday, June 6, 1996, at 10: 00 a.m. must be received by May 23, 1996.

ADDRESSES: Send submissions to: CC: DOM: CORP: R (INTL-0054- 95), room 5228, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington DC 20044. In the alternative, submissions may be hand delivered between the hours of 8 a.m. and 5 p.m. to CC: DOM: CORP: R (INTL-0054-95), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington DC. The public hearing will be held in the Auditorium, Internal Revenue Building, 1111 Constitution Avenue NW., Washington DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Ahmad Pirasteh or Richard Hoge, (202) 622-3870; and the hearing, Michael Slaughter (202) 622-7190 (not toll-free numbers).

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