[Code of Federal Regulations]
[Title 26, Volume 9]
[Revised as of April 1, 2008]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.863-1T]

[Page 280]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.863-1T  Allocation of gross income under section 863(a) (temporary).

    (a) through (d) [Reserved] For further guidance, see Sec. 1.863-
1(a) through (d).
    (e) Residual interest in a REMIC--(1) REMIC inducement fees. 
[Reserved] For further guidance, see Sec. 1.863-1(e)(1).
    (2) Excess inclusion income and net losses. An excess inclusion (as 
defined in section 860E(c)) shall be treated as income from sources 
within the United States. To the extent of excess inclusion income 
previously taken into account with respect to a residual interest 
(reduced by net losses previously taken into account under this 
paragraph), a net loss (described in section 860C(b)(2)) with respect to 
the residual interest shall be allocated to the class of gross income 
and apportioned to the statutory grouping(s) or residual grouping of 
gross income to which the excess inclusion income was assigned.
    (f) Effective date. Paragraph (e)(2) of this section applies for 
taxable years ending after August 1, 2006. For further guidance, see 
Sec. 1.863-1(f). This section will expire July 31, 2009.

[T.D. 9272, 71 FR 43366, Aug. 1, 2006]