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