Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Job Act; Correction
| Published date | 06 March 2019 |
| Citation | 84 FR 8050 |
| Record Number | 2019-03942 |
| Section | Proposed rules |
| Court | Internal Revenue Service,Treasury Department |
Federal Register, Volume 84 Issue 44 (Wednesday, March 6, 2019)
[Federal Register Volume 84, Number 44 (Wednesday, March 6, 2019)]
[Proposed Rules]
[Page 8050]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-03942]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-105600-18]
RIN 1545-BO62
Guidance Related to the Foreign Tax Credit, Including Guidance
Implementing Changes Made by the Tax Cuts and Job Act; 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 Friday,
December 7, 2018. The proposed regulations relate to the determination
of the foreign tax credit under the Internal Revenue Code.
DATES: Written or electronic comments and requests for a public hearing
were due by February 5, 2019.
ADDRESSES: Send submissions to CC:PA:LPD:PR (REG-105600-18), Room 5203,
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20224. Submissions may be hand delivered Monday through
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
105600-18), Courier's desk, Internal Revenue Service, 1111 Constitution
Avenue NW, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations
under Sec. Sec. 1.861-8 through 1.861-13, 1.861-17, and 1.904(b)-3,
Jeffrey P. Cowan, (202) 317-4924; concerning the proposed regulations
under Sec. Sec. 1.901(j)-1, 1.904-1 through 1.904-6, 1.904(f)-12, and
1.954-1, Jeffrey L. Parry, (202) 317-4916, and Larry R. Pounders, (202)
317-5465; concerning Sec. Sec. 1.78-1 and 1.960-1 through 1.960-7,
Suzanne M. Walsh, (202) 317-4908; concerning Sec. Sec. 1.965-5 and
1.965-7, Karen J. Cate, (202) 317-4667.
SUPPLEMENTARY INFORMATION:
Background
This correction to the notice of proposed rulemaking (REG-105600-
18) addresses provisions issued under sections 861, 904, and 965 of the
Internal Revenue Code.
Need for Correction
As published, the notice of proposed rulemaking (REG-105600-18)
contains errors that may prove to be misleading and are in need of
clarification.
Correction to Publication
Accordingly, the notice of proposed rulemaking (REG-105600-18),
that was the subject of FR Doc. 2018-26322, published December 7, 2018
at 83 FR 63200, is corrected as follows:
Sec. 1.861-9 [Corrected]
1. On page 63230, second column, the sixth line of amendatory
instruction 6, the language ``percent foreign owned corporations'' is
corrected to read ``percent owned foreign corporations''.
Sec. 1.904-5 [Corrected]
2. On page 63251, second column, paragraph (i)(2), the sixth line,
the language ``together with other any person that'' is corrected to
read ``together with any other person that''.
Sec. 1.904(f)-12 [Corrected]
3. On page 63254, second column, paragraph (j)(1)(ii), the sixth
line, the language ``beginning after December 31, 2018.'' is corrected
to read ``beginning after December 31, 2017.''.
Sec. 1.965-7 [Corrected]
4. On page 63266, second column, paragraph (e)(1)(iv)(B)(1), the
eighteenth line, the language ``If the amount of the net operating loss
carryover or carryback to the taxable year is reduced by reason of the
section 965(n) election to an amount less than the U.S. source loss
component of the net operating loss, the potential carryovers (or
carrybacks) of the separate limitation losses that are part of the net
operating loss are proportionately reduced as provided in Sec.
1.904(g)-3(b)(3)(ii).'' is corrected to read ``Therefore, if the amount
of the net operating loss carryover or carryback to the taxable year
(as reduced by reason of the section 965(n) election) exceeds the U.S.
source loss component of the net operating loss that is carried over
under Sec. 1.904(g)-3(b)(3)(i), but such excess is less than the
potential carryovers (or carrybacks) of the separate limitation losses
that are part of the net operating loss, the potential carryovers (or
carrybacks) are proportionately reduced as provided in Sec. 1.904(g)-
3(b)(3)(ii) or (iii), as applicable.''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-03942 Filed 3-5-19; 8:45 am]
BILLING CODE 4830-01-P
