Part III. Administrative, Procedural, and Miscellaneous

Interim Guidance With Respect to the Application of Treas. Reg. §1.883–3

Notice 2006–43

SECTION I. PURPOSE

This notice announces that the Treasury Department (Treasury) and the Internal Revenue Service (IRS) will amend the regulations under section 883 of the Internal Revenue Code (Code) to provide guidance regarding the proper interpretation of §1.883–3(b) in light of the repeal of section 954(a)(4) and (f) (foreign base company shipping provisions) by section 415 of the American Jobs Creation Act of 2004, Pub. L. No. 108–357, 118 Stat. 1418 (2004) (“AJCA”). Until such regulations are issued, taxpayers may rely on the rules set forth in this notice.