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RIN ID: RIN 1545-BG55
TD ID: [TD 9368]
SUBJECT CATEGORY: Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction
DOCUMENT SUMMARY: This document contains corrections to final and temporary
regulations (TD 9368) that were published in the Federal Register on [[Page 15064]]
Friday, December 21, 2007 (72 FR 72582) regarding the reduction of the
number of separate foreign tax credit limitation categories under
section 904(d) of the Internal Revenue Code. These regulations affect
taxpayers claiming foreign tax credits and provide guidance needed to
comply with the statutory changes made by the American Jobs Creation
Act of 2004 (AJCA).
SUMMARY: Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction,
The final and temporary regulations (TD 9368) that are the subject of the correction are under section 904 of the Internal Revenue Code. Need for Correction
As published, final and temporary regulations (TD 9368) contain errors that may prove to be misleading and are in need of
clarification.
Accordingly, the publication of the final and temporary regulations (TD 9368), which were the subject of FR Doc. E724782, is corrected as follows:
1. On page 72585, column 1, in the preamble, under the paragraph heading ``V. Post1986 Undistributed Earnings and Post1986 Foreign Income Taxes of a Foreign Corporation as of the End of the Corporation's Last Pre2007 Taxable Year'', second line of the first paragraph of the column, the language ``described in section 959(c)(1)(A),'' is corrected to read ``described in section 959(c)(1) and (2),''.
2. On page 72586, column 3, in the preamble, under the paragraph heading ``VI. Separate Limitation Losses and Overall Foreign Losses'', first line of the second paragraph of the column, the language ``Section 1.90412T(h)(4) provides that'' is corrected to read ``Section 1.904(f)12T(h)(4) provides that''.
3. On page 72586, column 3, in the preamble, under the paragraph heading ``VI. Separate Limitation Losses and Overall Foreign Losses'', first line of the third paragraph of the column, the language ``Section 1.90412T(h)(5) provides that'' is corrected to read ``Section 1.904(f)12T(h)(5) provides that''.
4. On page 72586, column 3, in the preamble, under the paragraph
heading ``VI. Separate Limitation Losses and Overall Foreign Losses'',
sixth line of the third paragraph of the column, the language ``rules
of Sec. 1.90412T(g)(1) and (2)'' is corrected to read ``rules of Sec. 1.904(f)12T(g)(1) and (2)''.
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E85683 Filed 32008; 8:45 am]
BILLING CODE 483001P
FOR FURTHER INFORMATION CONTACT Jeffrey L. Parry, (202) 622-3850 (not a tollfree number).
14 CFR Part 39 40 CFR Part 52 14 CFR Part 71 33 CFR Part 165 26 CFR Part 1 50 CFR Part 679 33 CFR Part 117 40 CFR Part 180 44 CFR Part 67 50 CFR Part 17 47 CFR Part 73 50 CFR Part 648 14 CFR Part 97 33 CFR Part 100 40 CFR Part 63 50 CFR Part 622 26 CFR Part 301 39 CFR Part 111 44 CFR Part 65 40 CFR Parts 52 and 81 40 CFR Part 271 14 CFR Part 23 47 CFR Part 76 40 CFR Part 300 21 CFR Part 522 50 CFR Part 660 50 CFR Part 229 47 CFR Part 64 7 CFR Part 301 14 CFR Part 25