2020-20419. Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax; Correcting Amendment
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Start Preamble
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Correcting amendments.
SUMMARY:
This document contains corrections to Treasury Decision 9902, which was published in the Federal Register on Thursday, July 23, 2020. Treasury Decision 9902 contained final regulations under the global intangible low-taxed income and subpart F income provisions of the Internal Revenue Code regarding the treatment of income that is subject to a high rate of foreign tax.
DATES:
This correction is effective on October 9, 2020.
Start Further InfoFOR FURTHER INFORMATION CONTACT:
Jorge M. Oben or Larry R. Pounders at (202) 317-6934 (not a toll-free number).
End Further Info End Preamble Start Supplemental InformationSUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9902) that are the subject of this correction are issued under section 951A of the Code.
Need for Correction
As published, the final regulations (TD 9902) contain errors that need to be corrected.
Start List of SubjectsList of Subjects in 26 CFR Part 1
- Income taxes
- Reporting and recordkeeping requirements
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
Start PartPART 1—INCOME TAXES
End Part Start Amendment PartParagraph 1. The authority citation for part 1 continues to read in part as follows:
End Amendment Part Start Amendment PartPar. 2. Section 1.951A-2 is amended by adding a sentence at the end of paragraph (c)(7)(viii)(E)(2)(ii) to read as follows:
End Amendment PartTested Income and tested loss.* * * * *(c) * * *
(7) * * *
(viii) * * *
(E) * * *
(2) * * *
(ii) * * * Notwithstanding the rule set forth in this paragraph (c)(7)(viii)(E)(2)(ii), a controlled foreign corporation is not a member of a CFC group if, as of the close of its CFC inclusion year, the controlled foreign corporation does not have a controlling domestic shareholder.
Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2020-20419 Filed 10-8-20; 8:45 am]
BILLING CODE 4830-01-P
Document Information
- Effective Date:
- 10/9/2020
- Published:
- 10/09/2020
- Department:
- Internal Revenue Service
- Entry Type:
- Rule
- Action:
- Correcting amendments.
- Document Number:
- 2020-20419
- Dates:
- This correction is effective on October 9, 2020.
- Pages:
- 64040-64040 (1 pages)
- Docket Numbers:
- TD 9902
- RINs:
- 1545-BP15: Guidance Regarding the Global Intangible Low-Taxed Income High Tax Exclusion
- RIN Links:
- https://www.federalregister.gov/regulations/1545-BP15/guidance-regarding-the-global-intangible-low-taxed-income-high-tax-exclusion
- Topics:
- Income taxes, Reporting and recordkeeping requirements
- PDF File:
- 2020-20419.pdf
- Supporting Documents:
- » Guidance: Income Subject to a High Rate of Foreign Tax;Correcting Amendment
- » Income Subject to a High Rate of Foreign Tax; Guidance
- » Guidance under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income): Correction
- » Guidance Under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income)
- CFR: (1)
- 26 CFR 1.951A-2