SERVICE ANNOUNCES NINE-MONTH EXTENSION FOR IDENTIFYING LIABILITIES OF A U.S. TRADE OR BUSINESS FOR BRANCH PROFITS TAX PURPOSES.

Notice 89-14

The Internal Revenue Service today announced that the date by which a foreign corporation must specifically identify liabilities that give rise to interest paid by a U.S. trade or business, as provided under section 1.884-4T(b)(1)(i)(B) of the Temporary Income Tax Regulations, is extended from January 3, 1989, to September 15, 1989. This extension allows taxpayers additional time to identify liabilities in view of the rules announced in Notice 88-133, 1988-52 I.R.B. 28, relating to the definition of interest paid by a U.S. trade or business. Thus, a foreign corporation may specifically identify liabilities that give rise to interest paid by a U.S. trade or business on or before September 15, 1989, notwithstanding the fact that it did not specifically identify such liabilities on or before January 3, 1989, or identified other liabilities on or before January 3, 1989. This document serves as an "administrative pronouncement" as that term is described in section 1.6661-3(b)(2) of the regulations and may be relied upon to the same extent as a revenue ruling or revenue procedure. The temporary regulations under section 884 will be amended to incorporate the rules of this notice, and such amendments will be effective for taxable years beginning after December 31, 1986. DRAFTING INFORMATION The principal author of this notice is Elizabeth U. Karzon of the Office of the Associate Chief Counsel (International). For further information about the notice, call Elizabeth U. Karzon at (202) 566-3160 (not a toll-free call), or write to CC:INTL, Room 5537, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, D.C. 20224.