Guidance Involving Hybrid Arrangements and the Allocation of Deductions Attributable to Certain Disqualified Payments Under Section 951A (Global Intangible Low-Taxed Income); Correction

Published date11 August 2020
Citation85 FR 48485
Record Number2020-15857
SectionProposed rules
CourtInternal Revenue Service
Federal Register, Volume 85 Issue 155 (Tuesday, August 11, 2020)
[Federal Register Volume 85, Number 155 (Tuesday, August 11, 2020)]
                [Proposed Rules]
                [Page 48485]
                From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
                [FR Doc No: 2020-15857]
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                DEPARTMENT OF THE TREASURY
                Internal Revenue Service
                26 CFR Part 1
                [REG-106013-19]
                RIN 1545-BP22
                Guidance Involving Hybrid Arrangements and the Allocation of
                Deductions Attributable to Certain Disqualified Payments Under Section
                951A (Global Intangible Low-Taxed Income); Correction
                AGENCY: Internal Revenue Service (IRS), Treasury.
                ACTION: Correction to a notice of proposed rulemaking.
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                SUMMARY: This document contains a correction to a notice of proposed
                rulemaking that was published in the Federal Register on April 8, 2020.
                The proposed regulations that adjust hybrid deduction accounts to take
                into account earnings and profits of a controlled foreign corporation
                that are included in income by a United States shareholder.
                DATES: This correction is effective on August 11, 2020 and is
                applicable beginning April 8, 2020.
                FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations
                under section 951A, Jorge M. Oben at (202) 317-6934; concerning all
                other proposed regulations, Richard F. Owens at (202) 317-6501 (not
                toll-free numbers).
                SUPPLEMENTARY INFORMATION:
                Background
                 The proposed regulations that are the subject of this correction
                are under section 245A of the Internal Revenue Code.
                Need for Correction
                 As published, the notice of proposed regulations (REG-106013-19)
                contained errors that need to be corrected.
                Correction of Publication
                 Accordingly, the notice of proposed rulemaking (REG-106013-19) that
                was the subject of FR Doc. 2020-05923, published at 85 FR 19858 (April
                8, 2020), is corrected to read as follows:
                Sec. 1.951A-2 [Corrected]
                0
                1. On page 19872, first column, the fifth line of paragraph (c)(6)(i),
                the language ``allocated or'' is corrected to read ``allocated and''.
                0
                2. On page 19872, the third line from the bottom of paragraph
                (c)(6)(iv)(A)(2), the language, ``allocated or'' is corrected to read
                ``allocated and''.
                0
                3. On page 19873, third column, the third line of paragraph
                (c)(6)(iv)(B)(2), the language, ``are allocated or'' is corrected to
                read ``are allocated and''.
                Martin V. Franks,
                Branch Chief, Publications and Regulations Branch, Legal Processing
                Division, Associate Chief Counsel, (Procedure and Administration).
                [FR Doc. 2020-15857 Filed 8-10-20; 8:45 am]
                BILLING CODE 4830-01-P
                

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