Internal Revenue Service (IRS), Treasury.
This document contains a correction to final regulations (TD 9360) that were published in the Federal Register on Thursday, September 27, 2007 (72 FR 54820) providing certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of section 1291 of the Internal Revenue Code even though the foreign corporation in which they own stock is no longer treated as a PFIC under section 1297(a) or (e) of the Code.
This correction is effective October 17, 2007.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Paul J. Carlino at (202) 622-3840 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations (TD 9360) that are the subject of this correction are under sections 1291, 1297 and 1298 of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9360) contain an error that may prove to be misleading and is in need of clarification.Start List of Subjects
List of Subjects in 26 CFR Part 1End List of Subjects
Correction of PublicationStart Amendment Part
Accordingly,End Amendment Part Start Part
PART 1—INCOME TAXES
Paragraph 1. The authority citation for part 1 continues to read, in part, as follows:
Par. 2. Section 1.1297-3 is amended by revising the fourth sentence of paragraph (e)(5)(ii) Example.(i) to read as follows:
(e) * * *
(5) * * *
(ii) * * *
* * *
(i) * * * In years 1993 and 1994, FC did not satisfy either the income or the asset test of section 1297(a). * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. E7-20489 Filed 10-16-07; 8:45 am]
BILLING CODE 4830-01-P