Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits:
Federal Register Volume 76, Number 168 (Tuesday, August 30, 2011)
Rules and Regulations
Page 53818
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
FR Doc No: 2011-22067
DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Part 1
REG-126519-11
RIN 1545-BK41
Determining the Amount of Taxes Paid for Purposes of the Foreign
Tax Credit; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to notice of proposed rulemaking by cross-reference to temporary regulations.
SUMMARY: This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations that were published in the Federal Register on Monday, July 18, 2011. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results.
FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622-3850 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11) that is the subject of this correction is under section 901 of the Internal Revenue Code.
Need for Correction
As published July 18, 2011 (76 FR 42076), the notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11) contains errors that may prove to be misleading and are in need of clarification.
Correction of Publication
Accordingly, the notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11), that was the subject of FR
Doc. 2011-17919, is corrected as follows:
Section 1.901-2 is amended by adding paragraphs
(e)(5)(iv)(B)(1)(iii) and (h)(3) to read as follows:
Sec. 1.901-2 Income, war profits, or excess profits tax paid or accrued.
* * * * *
(e) * * *
(5) * * *
(iv) * * *
(B) * * *
(1) * * *
(iii) [The text of proposed Sec. 1.901-2(e)(5)(iv)(B)(1)(iii) is the same as the text of Sec. 1.901-2T(e)(5)(iv)(B)(1)(iii) published elsewhere in this issue of the Federal Register.]
* * * * *
(h) * * *
(3) [The text of proposed Sec. 1.901-2(h)(3) is the same as the text of Sec. 1.901-2T(h)(3) published elsewhere in this issue of the
Federal Register.]
Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal
Processing Division, Associate Chief Counsel, Procedure and
Administration.
FR Doc. 2011-22067 Filed 8-29-11; 8:45 am
BILLING CODE 4830-01-P