Proposed Amendments to the Regulations on the Determination of Interest Expense Deduction of Foreign Corporations and Branch Profits Tax

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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.