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Partner's Distributive Share: Foreign Tax Expenditures; 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.

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AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendments.

SUMMARY:

This document contains correction to final regulations (TD 9292) that were published in the Federal Register on Thursday, October 19, 2006 (71 FR 61648) regarding the allocation of creditable foreign tax expenditures by partnerships.

DATES:

The correction is effective October 19, 2006.

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FOR FURTHER INFORMATION CONTACT:

Timothy J. Leska, (202) 622-3050 or Michael I. Gilman (202) 622-3850 (not toll-free numbers).

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SUPPLEMENTARY INFORMATION:

Background

The correction notice that is the subject of this document is under section 704 of the Internal Revenue Code.

Need for Correction

As published, final regulations (TD 9292) contain errors that may prove to be misleading and are in need of clarification.

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List of Subjects in 26 CFR Part 1

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Correction of Publication

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Accordingly,

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PART 1—INCOME TAXES

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

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1. * * *

2. The heading and text of paragraphs (b)(1)(ii)(b), and (b)(5) Examples 25 through 27 are revised.

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Partner's distributive share.
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Example 25. * * *

(ii) * * * Accordingly, the country X taxes will be reallocated according to the partners' interests in the partnership.

Example 26. * * *

(ii) * * * Because AB's partnership agreement allocates the $80,000 of country X taxes and $40,000 of country Y taxes in proportion to the distributive shares of income to which such taxes relate, the allocations are deemed to be in accordance with the partners' interests in the partnership under paragraph (b)(4)(viii) of this section.

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LaNita Van Dyke,

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

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[FR Doc. E6-20722 Filed 12-6-06; 8:45 am]

BILLING CODE 4830-01-P