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Rule

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

Action

Correction To Final And Temporary Regulations.

Summary

This document contains a correction to final and temporary regulations (TD 9536) that were published in the Federal Register on Monday, July 18, 2011, providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

 

Table of Contents Back to Top

DATES: Back to Top

This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

FOR FURTHER INFORMATION CONTACT: Back to Top

Jeffrey Cowan, (202) 622-3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION: Back to Top

Background Back to Top

The temporary and final regulation (TD 9536) that is the subject of this correction is under section 901 of the Internal Revenue Code.

Need for Correction Back to Top

As published July 18, 2011 (76 FR 42036), TD 9536 contains an error that may prove to be misleading and is in need of clarification.

Correction of Publication Back to Top

Accordingly, the publication of the final and temporary regulations (TD 9536), that were the subject of FR Doc. 2011-17916, is corrected as follows:

On page 42037, column 2, in the preamble under the caption “Explanation of Provision”, first paragraph, tenth line from the bottom, the language, “2(e)(5)(iv)(B)(1)(iii) that a foreign” is corrected to read “2T(e)(5)(iv)(B)(1)(iii) that a foreign”.

Treena V. Garrett,

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

[FR Doc. 2011-22066 Filed 8-29-11; 8:45 am]

BILLING CODE 4830-01-P

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