Skip to Content

We invite you to try out our new beta eCFR site at We’ve made big changes to make the eCFR easier to use. Be sure to leave feedback using the 'Help' button on the bottom right of each page!


Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction

Document Details

Information about this document as published in the Federal Register.

Document Statistics
Document page views are updated periodically throughout the day and are cumulative counts for this document. Counts are subject to sampling, reprocessing and revision (up or down) throughout the day.
Enhanced Content

Relevant information about this document from provides additional context. This information is not part of the official Federal Register document.

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


Internal Revenue Service (IRS), Treasury.


Final temporary regulations; correction.


This document contains a correction to a Treasury Decision 9865, which was published in the Federal Register on Tuesday, June 18, 2019. Treasury Decision 9865 contains temporary regulations under section 245A of the Internal Revenue Code (the “Code”) that limit the dividends received from current or former controlled foreign corporations.


Effective date: These regulations are effective August 8, 2019 and applicable June 18, 2019.

Start Further Info


Logan M. Kincheloe at (202) 317-6937 (not a toll-free number).

End Further Info End Preamble Start Supplemental Information



The final regulations (TD 9865) that are the subject of this correction are issued under sections 245A, 954, and 6038.

Need for Correction

As published, the final regulations (TD 9865), contains errors that may prove to be misleading and are in need of clarification.

Correction to Publication

Accordingly, the final regulations (TD 9865), that are the subject of FR 2019-12442, in the issue of June 18, 2019, are corrected as follows:

Start Amendment Part

1. On page 28398, in the third column, in the tenth line of the second full Start Printed Page 38867paragraph, “intangible lowed-taxed” is corrected to read “intangible low-taxed”.

End Amendment Part Start Amendment Part

2. On page 28403, in the third column, in the fifth line of the first partial paragraph, “§ 1.245A-5T(g)(3)(iv)” is corrected to read “§ 1.245A-5T(g)(4)(i)”.

End Amendment Part Start Amendment Part

3. On the same page, in the same column, in the twelfth line of the first full paragraph, “§ 1.245A-5T(g)(5)” is corrected to read “§ 1.245A-5T(g)(4)(i)”.

End Amendment Part Start Amendment Part

4. On page 28404, in the first column, under the heading “ A. In General”, in the second paragraph, “Explanations of Provisions” is corrected to read “Explanation of Provisions”.

End Amendment Part Start Signature

Martin V. Franks,

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

End Signature End Supplemental Information

[FR Doc. 2019-16631 Filed 8-7-19; 8:45 am]