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: 2011-22064
DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Part 1
TD 9535
RIN 1545-BK25
Determining the Amount of Taxes Paid for Purposes of the Foreign
Tax Credit; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to final and temporary regulations.
SUMMARY: This document contains a correction to final and temporary regulations (TD 9535), that were published in the Federal Register on
Monday, July 18, 2011. These regulations provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured transactions that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.
DATES: This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.
FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622-3850 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9535) that is the subject of this correction are under section 901 of Internal Revenue Code.
Need for Correction
As published, TD 9535 contains an error that may prove to be misleading and is in need of clarification.
Correction of Publication
Accordingly July 18, 2011 (76 FR 42038), the publication of the final and temporary regulations (TD 9535), that were the subject of FR
Doc. 2011-17920, is corrected as follows:
On page 42042, column 3, in the preamble under the caption ``K.
Effective Date'', line 5, the language, ``or after July 17, 2011.'' is corrected to read ``or after July 13, 2011.''.
Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal
Processing Division, Associate Chief Counsel (Procedure and
Administration).
FR Doc. 2011-22064 Filed 8-29-11; 8:45 am
BILLING CODE 4830-01-P
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