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Home » 2009 Issues » 74 FR (09/22/2009) » E9-22694. Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction

  E9-22694. Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction  

  • Start Preamble

    AGENCY:

    Internal Revenue Service (IRS), Treasury.

    ACTION:

    Correcting amendment.

    SUMMARY:

    This document contains corrections to final regulations (TD 9452) that were published in the Federal Register on Thursday, June 11, 2009, regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations.

    DATES:

    This correction is effective on September 22, 2009 and is applicable in taxable years ending on or after April 20, 2009.

    Start Further Info

    FOR FURTHER INFORMATION CONTACT:

    Richard Chewning, (202) 622-3850 (not a toll-free number).

    End Further Info End Preamble Start Supplemental Information

    SUPPLEMENTARY INFORMATION:

    Background

    The final regulations that are the subject of this document are under section 964 of the Internal Revenue Code.

    Need for Correction

    As published on Thursday, June 11, 2009 (74 FR 27886), the final regulations (TD 9452) contain errors that may prove to be misleading and are in need of clarification.

    Start List of Subjects

    List of Subjects in 26 CFR Part 1

    • Income taxes
    • Reporting and recordkeeping requirements
    End List of Subjects

    Correction of Publication

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    Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

    End Amendment Part Start Part

    PART 1—INCOME TAXES

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    Paragraph 1. The authority citation for part 1 continues to read in part as follows:

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    Authority: 26 U.S.C. 7805 * * *

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    Par. 2. Section 1.964-1 is amended by revising the last sentence of paragraph (c)(2) and paragraph (c)(4)(i)(D) to read as follows:

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    Determination of the earnings and profits of a foreign corporation.
    * * * * *

    (c) * * *

    (2) * * * See also §§ 1.985-5, 1.985-6, and 1.985-7 relating to adjustments to earnings and profits of a QBU required when the QBU changes its functional currency or begins to use the dollar approximate separate transactions method of accounting.

    (4) * * *

    (i) * * *

    (D) Whether the domestic shareholder received the written notice required by paragraph (c)(3)(iii) of this section.

    * * * * *
    Start Signature

    LaNita VanDyke,

    Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

    End Signature End Supplemental Information

    [FR Doc. E9-22694 Filed 9-21-09; 8:45 am]

    BILLING CODE 4830-01-P

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Document Information

Comments Received:
0 Comments
Effective Date:
9/22/2009
Published:
09/22/2009
Department:
Internal Revenue Service
Entry Type:
Rule
Action:
Correcting amendment.
Document Number:
E9-22694
Dates:
This correction is effective on September 22, 2009 and is applicable in taxable years ending on or after April 20, 2009.
Pages:
48151-48151 (1 pages)
Docket Numbers:
TD 9452
RINs:
1545-BB28: Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporation
RIN Links:
https://www.federalregister.gov/regulations/1545-BB28/application-of-separate-limitations-to-dividends-from-noncontrolled-section-902-corporation
Topics:
Income taxes, Reporting and recordkeeping requirements
PDF File:
e9-22694.pdf
CFR: (1)
26 CFR 1.964-1