2019-16631. Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction
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Start Preamble
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Final temporary regulations; correction.
SUMMARY:
This document contains a correction to a Treasury Decision 9865, which was published in the Federal Register on Tuesday, June 18, 2019. Treasury Decision 9865 contains temporary regulations under section 245A of the Internal Revenue Code (the “Code”) that limit the dividends received from current or former controlled foreign corporations.
DATES:
Effective date: These regulations are effective August 8, 2019 and applicable June 18, 2019.
Start Further InfoFOR FURTHER INFORMATION CONTACT:
Logan M. Kincheloe at (202) 317-6937 (not a toll-free number).
End Further Info End Preamble Start Supplemental InformationSUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9865) that are the subject of this correction are issued under sections 245A, 954, and 6038.
Need for Correction
As published, the final regulations (TD 9865), contains errors that may prove to be misleading and are in need of clarification.
Correction to Publication
Accordingly, the final regulations (TD 9865), that are the subject of FR 2019-12442, in the issue of June 18, 2019, are corrected as follows:
Start Amendment Part1. On page 28398, in the third column, in the tenth line of the second full Start Printed Page 38867paragraph, “intangible lowed-taxed” is corrected to read “intangible low-taxed”.
End Amendment Part Start Amendment Part2. On page 28403, in the third column, in the fifth line of the first partial paragraph, “§ 1.245A-5T(g)(3)(iv)” is corrected to read “§ 1.245A-5T(g)(4)(i)”.
End Amendment Part Start Amendment Part3. On the same page, in the same column, in the twelfth line of the first full paragraph, “§ 1.245A-5T(g)(5)” is corrected to read “§ 1.245A-5T(g)(4)(i)”.
End Amendment Part Start Amendment Part4. On page 28404, in the first column, under the heading “ A. In General”, in the second paragraph, “Explanations of Provisions” is corrected to read “Explanation of Provisions”.
End Amendment Part Start SignatureMartin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2019-16631 Filed 8-7-19; 8:45 am]
BILLING CODE 4830-01-P
Document Information
- Effective Date:
- 8/8/2019
- Published:
- 08/08/2019
- Department:
- Internal Revenue Service
- Entry Type:
- Rule
- Action:
- Final temporary regulations; correction.
- Document Number:
- 2019-16631
- Dates:
- Effective date: These regulations are effective August 8, 2019 and applicable June 18, 2019.
- Pages:
- 38866-38867 (2 pages)
- Docket Numbers:
- TD 9865
- RINs:
- 1545-BO64: Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
- RIN Links:
- https://www.federalregister.gov/regulations/1545-BO64/limitation-on-deduction-for-dividends-received-from-certain-foreign-corporations-and-amounts-eligibl
- PDF File:
- 2019-16631.Pdf
- Supporting Documents:
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
- » Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
- » Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Hearing
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction
- » Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction
- » Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
- » Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
- CFR: (1)
- 26 CFR 1