Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit, 53819 [2011-22065]
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Federal Register / Vol. 76, No. 168 / Tuesday, August 30, 2011 / Rules and Regulations
published in the Federal Register on
Monday, July 18, 2011, providing
guidance relating to the determination
of the amount of taxes paid for purposes
of the foreign tax credit. These
regulations address certain highly
structured arrangements that produce
inappropriate foreign tax credit results.
The regulations affect individuals and
corporations that claim direct and
indirect foreign tax credits.
DATES: This correction is effective
August 30, 2011, and is applicable
beginning July 18, 2011.
FOR FURTHER INFORMATION CONTACT:
Jeffrey Cowan, (202) 622–3850 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The temporary and final regulation
(TD 9536) that is the subject of this
correction is under section 901 of the
Internal Revenue Code.
Need for Correction
As published July 18, 2011 (76 FR
42036), TD 9536 contains an error that
may prove to be misleading and is in
need of clarification.
Correction of Publication
Accordingly, the publication of the
final and temporary regulations (TD
9536), that were the subject of FR Doc.
2011–17916, is corrected as follows:
On page 42037, column 2, in the
preamble under the caption
‘‘Explanation of Provision’’, first
paragraph, tenth line from the bottom,
the language, ‘‘2(e)(5)(iv)(B)(1)(iii) that a
foreign’’ is corrected to read
‘‘2T(e)(5)(iv)(B)(1)(iii) that a foreign’’.
This document contains
amendments to correct errors in final
and temporary regulations (TD 9536)
that were published in the Federal
Register on Monday, July 18, 2011,
providing guidance relating to the
determination of the amount of taxes
paid for purposes of the foreign tax
credit. These regulations address certain
highly structured arrangements that
produce inappropriate foreign tax credit
results. The regulations affect
individuals and corporations that claim
direct and indirect foreign tax credits.
DATES: This correction is effective on
August 30, 2011 and is applicable
beginning July 18, 2011.
FOR FURTHER INFORMATION CONTACT:
Jeffery Cowan, (202) 622–3850 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
Background
The temporary and final regulation
(TD 9536) that is the subject of this
correction is under section 901 of the
Internal Revenue Code.
Need for Correction
As published July 18, 2011 (76 FR
42036), TD 9536 contains errors that
may prove to be misleading and is in
need of clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
53819
§ 1.901–2T Income, war profits, or excess
profits tax paid or accrued.
(a) through (e)(5)(iv)(B)(1)(ii)
[Reserved]. For further guidance, see
§ 1.901–2(a) through (e)(5)(iv)(B)(1)(ii).
(iii) A foreign payment attributable to
income of the entity, within the
meaning of § 1.901–2(e)(5)(iv)(B)(1)(ii),
also includes a withholding tax (within
the meaning of section 901(k)(1)(B))
imposed on a dividend or other
distribution (including distributions
made by a pass-through entity or an
entity that is disregarded as an entity
separate from its owner for U.S. tax
purposes) with respect to the equity of
the entity.
(2) through (h)(2) [Reserved]. For
further guidance, see § 1.901–
2(e)(5)(iv)(B)(2) through (h)(2).
(h)(3) Effective/applicability date.
This section applies to foreign payments
that, if such payments were an amount
of tax paid, would be considered paid
or accrued under § 1.901–2(f) on or after
July 14, 2011.
(h)(4) Expiration date. The
applicability of this section expires on
July 14, 2014.
Treena V. Garrett,
Federal Register Liaison, Publication and
Regulations Branch, Legal Processing
Division, Associate Chief Counsel, (Procedure
and Administration).
[FR Doc. 2011–22065 Filed 8–29–11; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
PART 1—INCOME TAXES
26 CFR Part 1
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
[TD 9534]
Treena V. Garrett,
Federal Register Liaison, Publications and
Regulations Branch, Legal Processing
Division, Associate Chief Counsel, (Procedure
and Administration).
■
[FR Doc. 2011–22066 Filed 8–29–11; 8:45 am]
■
BILLING CODE 4830–01–P
Par. 2. Section 1.901–2 is amended by
adding paragraphs (e)(5)(iv)(B)(1)(iii)
and (h)(3) to read as follows:
Methods of Accounting Used by
Corporations That Acquire the Assets
of Other Corporations; Correction
DEPARTMENT OF THE TREASURY
§ 1.901–2 Income, war profits, or excess
profits tax paid or accrued.
AGENCY:
Internal Revenue Service
*
26 CFR Part 1
srobinson on DSK4SPTVN1PROD with RULES
[TD 9536]
RIN 1545–BK40
Determining the Amount of Taxes Paid
for Purposes of the Foreign Tax Credit
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendment.
AGENCY:
VerDate Mar<15>2010
18:46 Aug 29, 2011
Jkt 223001
RIN 1545–BD81
Authority: 26 U.S.C. 7805 * * *
*
*
*
*
(e) * * *
(5) * * *
(iv) * * *
(B) * * *
(1) * * *
(iii) [Reserved]. For further guidance,
see § 1.901–2T(e)(5)(iv)(B)(1)(iii).
*
*
*
*
*
(h) * * *
(3) [Reserved]. For further guidance,
see § 1.901–2T(h)(3).
■ Par. 3. Section 1.901–2T is added to
read as follows:
PO 00000
Frm 00009
Fmt 4700
Sfmt 4700
Internal Revenue Service (IRS),
Treasury.
ACTION: Correction to final regulations.
This document describes
corrections to final regulations (TD
9534) relating to the methods of
accounting, including the inventory
methods, to be used by corporations that
acquire the assets of other corporations
in certain corporate reorganizations and
tax-free liquidations. These regulations
were published in the Federal Register
on Monday, August 1, 2011.
DATES: This correction is effective on
August 31, 2011.
SUMMARY:
E:\FR\FM\30AUR1.SGM
30AUR1
Agencies
[Federal Register Volume 76, Number 168 (Tuesday, August 30, 2011)]
[Rules and Regulations]
[Page 53819]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-22065]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9536]
RIN 1545-BK40
Determining the Amount of Taxes Paid for Purposes of the Foreign
Tax Credit
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendment.
-----------------------------------------------------------------------
SUMMARY: This document contains amendments to correct errors in final
and temporary regulations (TD 9536) that were published in the Federal
Register on Monday, July 18, 2011, providing guidance relating to the
determination of the amount of taxes paid for purposes of the foreign
tax credit. These regulations address certain highly structured
arrangements that produce inappropriate foreign tax credit results. The
regulations affect individuals and corporations that claim direct and
indirect foreign tax credits.
DATES: This correction is effective on August 30, 2011 and is
applicable beginning July 18, 2011.
FOR FURTHER INFORMATION CONTACT: Jeffery Cowan, (202) 622-3850 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The temporary and final regulation (TD 9536) that is the subject of
this correction is under section 901 of the Internal Revenue Code.
Need for Correction
As published July 18, 2011 (76 FR 42036), TD 9536 contains errors
that may prove to be misleading and is in need of clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following
correcting amendments:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
0
Par. 2. Section 1.901-2 is amended by adding paragraphs
(e)(5)(iv)(B)(1)(iii) and (h)(3) to read as follows:
Sec. 1.901-2 Income, war profits, or excess profits tax paid or
accrued.
* * * * *
(e) * * *
(5) * * *
(iv) * * *
(B) * * *
(1) * * *
(iii) [Reserved]. For further guidance, see Sec. 1.901-
2T(e)(5)(iv)(B)(1)(iii).
* * * * *
(h) * * *
(3) [Reserved]. For further guidance, see Sec. 1.901-2T(h)(3).
0
Par. 3. Section 1.901-2T is added to read as follows:
Sec. 1.901-2T Income, war profits, or excess profits tax paid or
accrued.
(a) through (e)(5)(iv)(B)(1)(ii) [Reserved]. For further guidance,
see Sec. 1.901-2(a) through (e)(5)(iv)(B)(1)(ii).
(iii) A foreign payment attributable to income of the entity,
within the meaning of Sec. 1.901-2(e)(5)(iv)(B)(1)(ii), also includes
a withholding tax (within the meaning of section 901(k)(1)(B)) imposed
on a dividend or other distribution (including distributions made by a
pass-through entity or an entity that is disregarded as an entity
separate from its owner for U.S. tax purposes) with respect to the
equity of the entity.
(2) through (h)(2) [Reserved]. For further guidance, see Sec.
1.901-2(e)(5)(iv)(B)(2) through (h)(2).
(h)(3) Effective/applicability date. This section applies to
foreign payments that, if such payments were an amount of tax paid,
would be considered paid or accrued under Sec. 1.901-2(f) on or after
July 14, 2011.
(h)(4) Expiration date. The applicability of this section expires
on July 14, 2014.
Treena V. Garrett,
Federal Register Liaison, Publication and Regulations Branch, Legal
Processing Division, Associate Chief Counsel, (Procedure and
Administration).
[FR Doc. 2011-22065 Filed 8-29-11; 8:45 am]
BILLING CODE 4830-01-P