Internal Revenue Service (IRS), Treasury.
This document contains corrections to final regulations (TD 9452) that were published in the Federal Register on Thursday, June 11, 2009, regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations.
This correction is effective on September 22, 2009 and is applicable in taxable years ending on or after April 20, 2009.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Richard Chewning, (202) 622-3850 (not a toll-free number).End Further Info End Preamble Start Supplemental Information
The final regulations that are the subject of this document are under section 964 of the Internal Revenue Code.
Need for Correction
As published on Thursday, June 11, 2009 (74 FR 27886), the final regulations (TD 9452) contain errors that may prove to be misleading and are 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 TAXESEnd Part Start Amendment Part
End Amendment Part Start Amendment Part
End Amendment Part
(c) * * *
(2) * * * See also §§ 1.985-5, 1.985-6, and 1.985-7 relating to adjustments to earnings and profits of a QBU required when the QBU changes its functional currency or begins to use the dollar approximate separate transactions method of accounting.
(4) * * *
(i) * * *
(D) Whether the domestic shareholder received the written notice required by paragraph (c)(3)(iii) of this section.
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. E9-22694 Filed 9-21-09; 8:45 am]
BILLING CODE 4830-01-P