Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction, 27609-27610 [2011-11580]

Download as PDF Federal Register / Vol. 76, No. 92 / Thursday, May 12, 2011 / Rules and Regulations paragraph (b)(3)(ii) of this section, delivers cargo to the vessel carrier for lading aboard the vessel at the foreign port, the NVOCC, if licensed by or registered with the Federal Maritime Commission and in possession of an International Carrier Bond containing the provisions of § 113.64 of this chapter, may electronically transmit the corresponding required cargo declaration information directly to CBP through the vessel AMS system (or other system approved by CBP for this purpose). The information must be received 24 or more hours before the related cargo is laden aboard the vessel at the foreign port (see § 113.64(c) of this chapter), as provided in paragraph (b)(2) of this section, or in accordance with paragraph (b)(4) of this section applicable to exempted bulk and break bulk cargo. In the alternative, the NVOCC must fully disclose and present the required cargo declaration information for the related cargo to the vessel carrier which is required to present this information to CBP, in accordance with this section, via the vessel AMS system (or other CBPapproved system). * * * * * (4) Carriers of bulk cargo as specified in paragraph (b)(4)(i) of this section and carriers of break bulk cargo to the extent provided in paragraph (b)(4)(ii) of this section are exempt, with respect only to the bulk or break bulk cargo being transported, from the requirement set forth in paragraph (b)(2) of this section that an electronic cargo declaration be received by CBP 24 hours before such cargo is laden aboard the vessel at the foreign port. With respect to exempted carriers of bulk or break bulk cargo operating voyages to the United States, CBP must receive the electronic cargo declaration covering the bulk or break bulk cargo they are transporting 24 hours prior to the vessel’s arrival in the United States (see § 4.30(n)). However, for any containerized or non-qualifying break bulk cargo these exempted carriers will be transporting, CBP must receive the electronic cargo declaration 24 hours in advance of loading. * * * * * wwoods2 on DSK1DXX6B1PROD with RULES_PART 1 § 4.7a [Amended] 3. Section 4.7a is amended by: a. In paragraph (a), removing the words ‘‘Customs Form’’ and adding in their place the words ‘‘CBP Form’’; ■ b. In paragraph (b), removing the words ‘‘Customs Form’’ wherever they appear and adding in their place the words ‘‘CBP Form’’ and removing the words ‘‘Customs and Immigration Form I–418’’ and adding in their place the ■ ■ VerDate Mar<15>2010 12:42 May 11, 2011 Jkt 223001 words ‘‘CBP Form I–418’’, and, in the certification language, removing the word ‘‘Customs’’ and adding in its place ‘‘CBP’’; ■ c. In paragraph (c)(1), removing from the first parenthetical in the first sentence the words ‘‘Customs Form 1302 or a Customs-approved electronic equivalent’’ and adding in their place the words ‘‘CBP Form 1302 submitted in accordance with paragraph (b)(2) or (b)(4) of this section’’; ■ d. In paragraph (c)(2)(ii), removing the words ‘‘Customs Form’’ wherever they appear and adding in their place the words ‘‘CBP Form’’; ■ e. In paragraph (c)(2)(iii), removing the word ‘‘Customs’’ wherever it appears and adding in its place ‘‘CBP’’ and, in the next to last sentence, removing the words ‘‘discrepancies between manifests and entries’’ and adding in their place the words ‘‘discrepancies between cargo declarations and entries’’; ■ f. In paragraph (c)(3) introductory text, removing the word ‘‘Customs’’ and adding in its place ‘‘CBP’’; ■ g. In paragraph (c)(4) introductory text, removing the words ‘‘cargo manifest information’’ and adding in their place the words ‘‘cargo declaration information’’ and removing the words ‘‘, either on Customs Form 1302, or on a separate sheet or Customs-approved electronic equivalent,’’; ■ h. In paragraph (c)(4)(xv) introductory text, in the second parenthetical, which is within the first parenthetical, after the reference to § 4.7(b)(2), adding ‘‘or § 4.7(b)(4)’’ and, in paragraph (c)(4)(xv)(B), removing the words ‘‘Customs Form (CF) 3171 and adding in their place the words ‘‘CBP Form 3171’’; ■ i. In paragraph (d), removing the words ‘‘the Immigration and Naturalization Service, United States Department of Justice’’ and adding in their place the words ‘‘applicable Department of Homeland Security (DHS) regulations administered by CBP’’; ■ j. In paragraph (e)(1), removing the words ‘‘the Immigration and Naturalization Service, United States Department of Justice’’ and adding in their place the words ‘‘applicable DHS regulations administered by CBP’’ and, in the certification language, removing the word ‘‘Customs’’ wherever it appears and adding in its place ‘‘CBP’’; and ■ k. In paragraph (f), second sentence, removing the words ‘‘cargo manifest information to Customs’’ and adding in their place the words ‘‘cargo declaration information to CBP’’. § 4.8 ■ [Amended] 4. Section 4.8 is amended by: PO 00000 Frm 00007 Fmt 4700 Sfmt 4700 27609 a. In paragraph (a), removing the words ‘‘the Customs Service’’ and adding in their place the words ‘‘Customs and Border Protection (CBP)’’; and ■ b. In paragraph (b), removing the word ‘‘Customs’’ wherever it appears and adding in its place ‘‘CBP’’; in the second sentence, removing ‘‘(CF)’’; removing the words ‘‘in the manner provided in § 4.7(b)(2)’’ and the words ‘‘in the manner provided in § 4.7(b)’’ and adding in both places the words ‘‘in the manner provided in § 4.7(b)(2) or (4)’’; and, in the fourth and fifth sentences, removing ‘‘CF’’ and adding in its place the words ‘‘CBP Form’’. ■ 5. In § 4.30, paragraph (n) is revised to read as follows: ■ § 4.30 Permits and special licenses for unlading and lading. * * * * * (n) CBP will not issue a permit to unlade before it has received the cargo declaration information pursuant to § 4.7(b)(2) or (4) of this part. In cases in which CBP does not receive complete cargo declaration information from the carrier or a NVOCC in the manner, format, and time frame required by § 4.7(b)(2) or (4), as appropriate, CBP may delay issuance of the permit to unlade the entire vessel until all required information is received. CBP may also decline to issue a permit to unlade the specific cargo for which a cargo declaration is not received in a timely manner under § 4.7(b)(2) or (4). Further, where a carrier does not transmit a cargo declaration in the manner required by § 4.7(b)(2) or (4), preliminary entry pursuant to § 4.8(b) will be denied. Dated: May 4, 2011. Alan D. Bersin, Commissioner, U.S. Customs and Border Protection. [FR Doc. 2011–11248 Filed 5–11–11; 8:45 am] BILLING CODE 9111–14–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9521] RIN 1545–BG54 Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction Internal Revenue Service (IRS), Treasury. ACTION: Correction to final regulations. AGENCY: E:\FR\FM\12MYR1.SGM 12MYR1 27610 Federal Register / Vol. 76, No. 92 / Thursday, May 12, 2011 / Rules and Regulations This document describes corrections to final regulations (TD 9521) that were published in the Federal Register on Thursday, April 7, 2011, providing guidance relating to the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Internal Revenue Code. SUMMARY: This correction is effective on May 12, 2011, and is applicable on April 7, 2011. DATES: FOR FURTHER INFORMATION CONTACT: Jeffrey L. Parry, (202) 622–3850 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the subject of this correction are under section 904 of the Internal Revenue Code. Need for Correction As published on Thursday, April 7, 2011 (76 FR 19268), final regulations (TD 9521) contain errors that may prove to be misleading and are in need of clarification. wwoods2 on DSK1DXX6B1PROD with RULES_PART 1 Correction of Publication Accordingly, the publication of the final regulations (TD 9521) which were the subject of FR Doc. 2011–8229 is corrected as follows: 1. On page 19268, column 2, in the preamble, under the paragraph heading ‘‘II. Losses in and Losses With Respect to the Pre-2007 Separate Category for High Withholding Tax Interest’’, line 9 from the last paragraph of the column, the language ‘‘7T(g)(ii)) that offset U.S. source income’’ is corrected to read ‘‘7T(g)(1)(ii)) that offset U.S. source income’’. 2. On page 19269, column 1, in the preamble, under the paragraph heading ‘‘II. Losses in and Losses With Respect to the Pre-2007 Separate Category for High Withholding Tax Interest’’, the last sentence of first paragraph of the column, the language ‘‘The regulations have also been revised to clarify that, in the case of a financial services entity, to the extent an SLL in the post-2006 separate category for general category income is recaptured as income in the post-2006 separate category for passive category income, the amount that would otherwise be recaptured as passive income (as opposed to specified passive VerDate Mar<15>2010 12:42 May 11, 2011 Jkt 223001 Protection Agency, Region III, 1650 Arch Street, Philadelphia, Pennsylvania 19103. LaNita Van Dyke, D. Hand Delivery: At the previouslyChief, Publications and Regulations Branch, listed EPA Region III address. Such Legal Processing Division, Associate Chief deliveries are only accepted during the Counsel (Procedure and Administration). Docket’s normal hours of operation, and [FR Doc. 2011–11580 Filed 5–11–11; 8:45 am] special arrangements should be made BILLING CODE 4830–01–P for deliveries of boxed information. Instructions: Direct your comments to Docket ID No. EPA–R03–OAR–2011– ENVIRONMENTAL PROTECTION 0142. EPA’s policy is that all comments AGENCY received will be included in the public docket without change, and may be 40 CFR Part 52 made available online at www.regulations.gov, including any [EPA–R03–OAR–2011–0142; FRL–9304–2] personal information provided, unless the comment includes information Approval and Promulgation of Air claimed to be Confidential Business Quality Implementation Plans; Information (CBI) or other information Maryland; Adoption of Control whose disclosure is restricted by statute. Techniques Guidelines for Large Do not submit information that you Appliance Coatings consider to be CBI or otherwise AGENCY: Environmental Protection protected through www.regulations.gov Agency (EPA). or e-mail. The www.regulations.gov ACTION: Direct final rule. website is an anonymous access system, which means EPA will not know your SUMMARY: EPA is taking direct final identity or contact information unless action to approve a State you provide it in the body of your Implementation Plan (SIP) revision comment. If you send an e-mail submitted by the Maryland Department comment directly to EPA without going of the Environment (MDE). This SIP through www.regulations.gov, your erevision includes amendments to mail address will be automatically Maryland’s regulation for Volatile captured and included as part of the Organic Compounds from Specific comment that is placed in the public Processes and meets the requirement to docket and made available on the adopt Reasonably Available Control Internet. If you submit an electronic Technology (RACT) for sources covered comment, EPA recommends that you by EPA’s Control Techniques include your name and other contact Guidelines (CTG) standards for large information in the body of your appliance coatings. These amendments comment and with any disk or CD–ROM will reduce emissions of volatile organic you submit. If EPA cannot read your compound (VOC) emissions from large comment due to technical difficulties appliance coating facilities. Therefore, and cannot contact you for clarification, this revision will help Maryland attain EPA may not be able to consider your and maintain the national ambient air comment. Electronic files should avoid quality standard (NAAQS) for ozone. the use of special characters, any form This action is being taken under the of encryption, and be free of any defects Clean Air Act (CAA). or viruses. DATES: This rule is effective on July 11, Docket: All documents in the 2011 without further notice, unless EPA electronic docket are listed in the receives adverse written comment by www.regulations.gov index. Although June 13, 2011. If EPA receives such listed in the index, some information is comments, it will publish a timely not publicly available, i.e., CBI or other withdrawal of the direct final rule in the information whose disclosure is Federal Register and inform the public restricted by statute. Certain other that the rule will not take effect. material, such as copyrighted material, is not placed on the Internet and will be ADDRESSES: Submit your comments, publicly available only in hard copy identified by Docket ID Number EPA– form. Publicly available docket R03–OAR–2011–0142, by one of the materials are available either following methods: electronically in www.regulations.gov or A. www.regulations.gov. Follow the in hard copy during normal business on-line instructions for submitting hours at the Air Protection Division, comments. B. E-mail: fernandez.cristina@epa.gov. U.S. Environmental Protection Agency, Region III, 1650 Arch Street, C. Mail: EPA–R03–OAR–2011–0142, Philadelphia, Pennsylvania 19103. Cristina Fernandez, Associate Director, Copies of the State submittal are Office of Air Program Planning, available at the Maryland Department of Mailcode 3AP30, U.S. Environmental category income) will be recaptured as general category income.’’ is removed. PO 00000 Frm 00008 Fmt 4700 Sfmt 4700 E:\FR\FM\12MYR1.SGM 12MYR1

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[Federal Register Volume 76, Number 92 (Thursday, May 12, 2011)]
[Rules and Regulations]
[Pages 27609-27610]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-11580]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9521]
RIN 1545-BG54


Reduction of Foreign Tax Credit Limitation Categories Under 
Section 904(d); Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

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[[Page 27610]]

SUMMARY: This document describes corrections to final regulations (TD 
9521) that were published in the Federal Register on Thursday, April 7, 
2011, providing guidance relating to the reduction of the number of 
separate foreign tax credit limitation categories under section 904(d) 
of the Internal Revenue Code.

DATES: This correction is effective on May 12, 2011, and is applicable 
on April 7, 2011.

FOR FURTHER INFORMATION CONTACT: Jeffrey L. Parry, (202) 622-3850 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations that are the subject of this correction are 
under section 904 of the Internal Revenue Code.

Need for Correction

    As published on Thursday, April 7, 2011 (76 FR 19268), final 
regulations (TD 9521) contain errors that may prove to be misleading 
and are in need of clarification.

Correction of Publication

    Accordingly, the publication of the final regulations (TD 9521) 
which were the subject of FR Doc. 2011-8229 is corrected as follows:
    1. On page 19268, column 2, in the preamble, under the paragraph 
heading ``II. Losses in and Losses With Respect to the Pre-2007 
Separate Category for High Withholding Tax Interest'', line 9 from the 
last paragraph of the column, the language ``7T(g)(ii)) that offset 
U.S. source income'' is corrected to read ``7T(g)(1)(ii)) that offset 
U.S. source income''.
    2. On page 19269, column 1, in the preamble, under the paragraph 
heading ``II. Losses in and Losses With Respect to the Pre-2007 
Separate Category for High Withholding Tax Interest'', the last 
sentence of first paragraph of the column, the language ``The 
regulations have also been revised to clarify that, in the case of a 
financial services entity, to the extent an SLL in the post-2006 
separate category for general category income is recaptured as income 
in the post-2006 separate category for passive category income, the 
amount that would otherwise be recaptured as passive income (as opposed 
to specified passive category income) will be recaptured as general 
category income.'' is removed.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2011-11580 Filed 5-11-11; 8:45 am]
BILLING CODE 4830-01-P