[Federal Register Volume 80, Number 160 (Wednesday, August 19, 2015)]
[Proposed Rules]
[Page 50240]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-20476]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-115452-14]
RIN 1545-BM12


Disguised Payments for Services; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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SUMMARY: This document contains corrections to a notice of proposed 
rulemaking (REG-115452-14) that was published in the Federal Register 
on Thursday, July 23, 2015 (80 FR 43652). The proposed regulations are 
relating to disguised payments for services under section 707(a)(2)(A) 
of the Internal Revenue Code. The proposed regulations provide guidance 
to partnerships and their partners regarding when an arrangement will 
be treated as a disguised payment for services.

DATES: Written or electronic comments and requests for a public hearing 
for the notice of proposed rulemaking published at 80 FR 43625, July 
23, 2015, are still being accepted and must be received by October 21, 
2015.

FOR FURTHER INFORMATION CONTACT: Jaclyn Goldberg at (202) 317-6850 (not 
a toll free number).

SUPPLEMENTARY INFORMATION: 

Background

    The notice of proposed rulemaking (REG-115452-14) that is the 
subject of these corrections is under section 707 of the Internal 
Revenue Code.

Need for Correction

    As published, the notice of proposed (REG-115452-14) contains 
errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-115452-14), 
that was the subject of FR Doc. 2015-17828, is corrected as follows:
    1. On page 43652, in the preamble, first column, under the caption 
ADDRESSES, the eleventh line of the paragraph, the language 
``Washington, DC, or sent electronically, '' is corrected to read 
``Washington, DC, 20224 or sent electronically,''.
    2. On page 43653, in the preamble, first column, the tenth line 
from the bottom of the first full paragraph, the language ``gross 
income allocation in a nonpartner'' is corrected to read ``gross income 
allocation in a non-partner''.
    3. On page 43655, in the preamble, second column, the third line 
from the bottom of the second full paragraph, the language ``66-95 and 
revise Rev. Rul. 69-180,'' is corrected to read ``66-95 and Rev. Rul. 
69-180,''.
    4. On page 43657, in the preamble, third column, under the 
paragraph heading ``Drafting Information'' the third line of the 
paragraph, the language ``Goldberg of the Office Assistant Chief'' is 
corrected to read ``Goldberg of the Office Associate Chief''.


Sec.  1.707-2  [Corrected]

    5. On page 46358, column 3, paragraph (c), the eighth and ninth 
lines, the language ``arrangement constitutes in whole or in part a 
payment for services. The'' is corrected to read ``arrangement 
constitutes (in whole or in part) a payment for services. The.''.
    6. On page 43659, column 1, paragraph (d) Example 1, the twelfth 
line, the language ``first two years of partnership's operations.'' is 
corrected to read ``first two years of the partnership's operations.''.
    7. On page 43660, column 1, paragraph (d), Example 3 (iv), the 
sixteenth line, the language ``the presence or absence of 
entrepreneurial'' is corrected to read ``the presence or absence of 
significant entrepreneurial''.
    8. On page 43660, column 1, paragraph (d), Example 4 (ii), the last 
line of the column, the language ``entrepreneurial risk. The special 
allocation to'' is corrected to read ``significant entrepreneurial 
risk. The special allocation to''.
    9. On page 43660, column 3, paragraph (d), Example 6 (ii), the 
fourth line from the bottom of the column, the language ``waiver of the 
partnership. The ABC'' is corrected to read ``waiver of the fee. The 
ABC''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-20476 Filed 8-18-15; 8:45 am]
 BILLING CODE 4830-01-P