Skip to Content

Rule

Guidance Under Section 951 for Determining Pro Rata Share; Correction

Document Details

Information about this document as published in the Federal Register.

Published Document

This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.

Start Preamble

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document corrects final regulations (TD 9222) that were published in the Federal Register on Thursday, August 25, 2005 (70 FR 49864). The final regulations under section 951(a) of the Internal Revenue Code (Code) provide guidance for determining a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations.

DATES:

This correction is effective August 25, 2005.

Start Further Info

FOR FURTHER INFORMATION CONTACT:

Jeffrey L. Vinnik, (202) 622-3840 (not a toll-free number).

End Further Info End Preamble Start Supplemental Information

SUPPLEMENTARY INFORMATION:

Background

The final regulations (TD 9222) that are the subject of this correction are under section 951(a) of the Internal Revenue Code.

Need for Correction

As published, the final regulations (TD 9222) contain errors that may prove to be misleading and are in need of clarification.

Start List of Subjects

List of Subjects 26 CFR Part 1

End List of Subjects Start Printed Page 67906

Correction of Publication

Start Amendment Part

Accordingly,

End Amendment Part Start Part

PART 1—INCOME TAXES

End Part Start Amendment Part

End Amendment Part Start Authority

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

End Authority
[Corrected]
Start Amendment Part

1. In § 1.951-1(a), the undesignated paragraph is designated as paragraph (a)(3).

End Amendment Part Start Amendment Part

2. Section 1.951-1(e)(6), paragraph (ii) of

End Amendment Part Start Amendment Part

3. Section 1.951-1(e)(6), paragraph (i) of

End Amendment Part Start Amendment Part

4. Section 1.951-1(e)(6), paragraph (i) of

End Amendment Part Start Signature

Cynthia E. Grigsby,

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

End Signature End Supplemental Information

[FR Doc. 05-22260 Filed 11-8-05; 8:45 am]

BILLING CODE 4830-01-P