Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction

• Published date: 08 August 2019
• Citation: 84 FR 38892
• Record Number: 2019-16632
• Section: Proposed rules
• Court: Internal Revenue Service,Treasury Department

Federal Register, Volume 84 Issue 153 (Thursday, August 8, 2019)

[Federal Register Volume 84, Number 153 (Thursday, August 8, 2019)]
                [Proposed Rules]
                [Pages 38892-38893]
                From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
                [FR Doc No: 2019-16632]
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                DEPARTMENT OF THE TREASURY
                Internal Revenue Service
                26 CFR Part 1
                [REG-106282-18]
                RIN 1545-BP35
                Limitation on Deduction for Dividends Received From Certain
                Foreign Corporations and Amounts Eligible for Section 954 Look-Through
                Exception; Correction
                AGENCY: Internal Revenue Service (IRS), Treasury.
                ACTION: Correction to a notice of proposed rulemaking by cross-
                reference to temporary regulations.
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                SUMMARY: This document contains a correction to notice of proposed
                rulemaking by cross-reference to temporary regulations (REG-106282-18)
                that was published in the Federal Register on Tuesday, June 18, 2019.
                DATES: Written or electronic comments and requests for a public hearing
                for the notice of proposed rulemaking by cross-reference to temporary
                regulations at 84 FR 28426, June 18, 2019, are still being accepted and
                must be received by September 16, 2019.
                ADDRESSES: Send Submissions to CC:PA:LPD:PR (REG-106282-18), Room 5203,
                Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
                Washington, DC 20044. 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-
                106282-18), Courier's Desk, Internal Revenue Service, 1111 Constitution
                Avenue NW, Washington, DC 20224. Alternatively, taxpayers may submit
                comments electronically, via the Federal eRulemaking Portal at http://www.regulations.gov (IRS REG-106282-18).
                FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
                Logan M. Kincheloe, (202) 317-6937; concerning submission of comments
                and/or requests for a hearing Regina Johnson at (202) 317-6901 (not
                toll-free numbers).
                SUPPLEMENTARY INFORMATION:
                Background
                 This correction to the notice of proposed rulemaking (REG-106282-
                18) that is the subject of this document is issued under sections 245A,
                954, and 6038 of the Internal Revenue Code.
                Need for Correction
                 As published, the notice of proposed rulemaking by cross-reference
                to temporary regulations (REG-106282-18) contains errors that may prove
                to be misleading and are in need of clarification.
                Correction to Publication
                 Accordingly, the notice of proposed rulemaking by cross-reference
                to temporary regulations, FR 2019-12441, published at 84 FR 28426, June
                18, 2019, is corrected as follows:
                0
                1. On page 28426, the first column, under the caption SUMMARY, the
                third line from the bottom of the last paragraph, the language
                ``controlled foreign that receive certain'' is corrected to read
                ``controlled foreign corporations that receive certain''.
                0
                2. On page 28427, in the first column, under the last line of the
                paragraph before the caption Comments and Request Public Hearing
                section add the following sections:
                III. Unfunded Mandates Reform Act
                 The assessment of costs and benefits under the Unfunded Mandated
                Reform Act of these proposed regulations are explained in the temporary
                regulations under 245A, 954(c)(6), and 6038 published in 84 FR 28398
                (June 18, 2019).
                IV. Executive Order 13132: Federalism
                 The assessment of the federalism implications as required under
                Executive Order 13132 of these proposed regulations is explained in the
                temporary regulations under sections 245A, 954(c)(6), and 6038
                published in 84 FR 28398 (June 18, 2019).
                Sec. 1.245A-1 [Corrected]
                0
                3. On page 28427, second column, the amendatory instruction Par, 2, the
                [[Page 38893]]
                language ``Reserved sections 1.245A-1 through and Sec. 1.245A-5 are
                added to read as follows:'' is corrected to read ``Add and reserve
                Sec. Sec. 1.245A-1 through 1.245A-4 and add Sec. 1.245A-5 to read as
                follows: ''.
                Martin V. Franks,
                Chief, Publications and Regulations Branch, Legal Processing Division,
                Associate Chief Counsel, (Procedure and Administration).
                [FR Doc. 2019-16632 Filed 8-7-19; 8:45 am]
                BILLING CODE 4830-01-P