Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment, 38866 [2019-16630]

Download as PDF 38866 Federal Register / Vol. 84, No. 153 / Thursday, August 8, 2019 / Rules and Regulations Paragraph 6005 Class E Airspace Areas Extending Upward From 700 Feet or More Above the Surface of the Earth. * * * ACE IA E5 * Correction of Publication Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments: * Sioux Center, IA [Removed] Issued in Fort Worth, Texas, on July 31, 2019. John Witucki, Acting Manager, Operations Support Group, ATO Central Service Center. [FR Doc. 2019–16800 Filed 8–7–19; 8:45 am] DEPARTMENT OF THE TREASURY 26 CFR Part 1 RIN 1545–BO64 Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. AGENCY: This document contains corrections to Treasury Decision 9865, which was published in the Federal Register for Tuesday, June 18, 2019. Treasury Decision 9865 contained temporary regulations under section 245A of the Internal Revenue Code (the ‘‘Code) that limit the dividends received deduction available for certain dividends received from current or former controlled foreign corporations. DATES: Effective date. These corrections are effective on August 8, 2019 and applicable June 18, 2019. FOR FURTHER INFORMATION CONTACT: Logan M. Kincheloe at (202) 317–6937 (not a toll-free number). SUPPLEMENTARY INFORMATION: SUMMARY: Background The temporary regulations (TD 9865) that are the subject of this correction are under sections 245A, 954(c)(6), and 6038 of the Internal Revenue Code. Need for Correction jbell on DSK3GLQ082PROD with RULES * * * * As published June 18, 2019 (84 FR 28398), the temporary regulations (TD 9865; FR 2019–12442) contained errors that may prove misleading and therefore need to be corrected. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Jkt 247001 [FR Doc. 2019–16630 Filed 8–7–19; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF THE TREASURY §§ 1.245A–1T through 1.245A–4T [Reserved] Internal Revenue Service Par. 2. Reserved §§ 1.245A–1 through 1.245A–4 are revised to read §§ 1.245A– 1T through 1.245A–4T [Reserved]. 26 CFR Part 1 Par. 3. Section 1.245A–5T is amended by: ■ 1. In the first sentence of paragraph (c)(3)(i)(B), removing ‘‘a SFC’’ and adding in its place ‘‘an SFC’’. ■ 2. Adding two sentences at the end of paragraph (c)(3)(iv). ■ 3. In paragraphs (e)(3)(i)(C)(1) and (2), removing ‘‘required by paragraph (e)(3)(iv)’’ and adding in its place ‘‘described in paragraph (e)(3)(i)(D)’’. ■ 4. In paragraph (e)(3)(i)(D), removing ‘‘(e)(3)(iii)’’ and adding in its place ‘‘(e)(3)(i)(C)’’. ■ 5. In paragraph (e)(3)(ii), removing ‘‘amount with’’ and adding in its place ‘‘amount (or, with respect to a lower-tier CFC, a tiered extraordinary reduction amount under paragraph (f) of this section) with’’. The additions read as follows: ■ [TD 9865] Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). Authority: 26 U.S.C. 7805 * * * ■ Internal Revenue Service 15:42 Aug 07, 2019 Paragraph 1. The authority citation continues to read in part as follows: ■ * BILLING CODE 4910–13–P VerDate Sep<11>2014 PART 1—INCOME TAXES respect to such property during the disqualified period. * * * * * § 1.245A–5T Limitation of section 245A deduction and section 954(c)(6) exception (temporary). * * * * * (c) * * * (3) * * * (iv) * * * Specified property is also property with respect to which a loss was recognized during the disqualified period if the loss is properly allocable to income not described in section 951A(c)(2)(A)(i)(I) through (V) under the principles of section 954(b)(5) (specified loss). If only a portion of the loss recognized with respect to property during the disqualified period is specified loss, then a portion of the property is treated as specified property in an amount that bears the same ratio to the value of the property as the amount of specified loss bears to the total amount of loss recognized with PO 00000 Frm 00018 Fmt 4700 Sfmt 4700 [TD 9865] RIN 1545–BO64 Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction Internal Revenue Service (IRS), Treasury. ACTION: Final temporary regulations; correction. AGENCY: 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. DATES: Effective date: These regulations are effective August 8, 2019 and applicable June 18, 2019. FOR FURTHER INFORMATION CONTACT: Logan M. Kincheloe at (202) 317–6937 (not a toll-free number). SUPPLEMENTARY INFORMATION: SUMMARY: Background 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: ■ 1. On page 28398, in the third column, in the tenth line of the second full E:\FR\FM\08AUR1.SGM 08AUR1

Agencies

[Federal Register Volume 84, Number 153 (Thursday, August 8, 2019)]
[Rules and Regulations]
[Page 38866]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-16630]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9865]
RIN 1545-BO64


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

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

-----------------------------------------------------------------------

SUMMARY: This document contains corrections to Treasury Decision 9865, 
which was published in the Federal Register for Tuesday, June 18, 2019. 
Treasury Decision 9865 contained temporary regulations under section 
245A of the Internal Revenue Code (the ``Code) that limit the dividends 
received deduction available for certain dividends received from 
current or former controlled foreign corporations.

DATES: Effective date. These corrections are effective on August 8, 
2019 and applicable June 18, 2019.

FOR FURTHER INFORMATION CONTACT: Logan M. Kincheloe at (202) 317-6937 
(not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The temporary regulations (TD 9865) that are the subject of this 
correction are under sections 245A, 954(c)(6), and 6038 of the Internal 
Revenue Code.

Need for Correction

    As published June 18, 2019 (84 FR 28398), the temporary regulations 
(TD 9865; FR 2019-12442) contained errors that may prove misleading and 
therefore need to be corrected.

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 continues to read in part as 
follows:

    Authority: 26 U.S.C. 7805 * * *
* * * * *


Sec. Sec.  1.245A-1T through 1.245A-4T   [Reserved]

0
Par. 2. Reserved Sec. Sec.  1.245A-1 through 1.245A-4 are revised to 
read Sec. Sec.  1.245A-1T through 1.245A-4T [Reserved].

0
Par. 3. Section 1.245A-5T is amended by:
0
1. In the first sentence of paragraph (c)(3)(i)(B), removing ``a SFC'' 
and adding in its place ``an SFC''.
0
2. Adding two sentences at the end of paragraph (c)(3)(iv).
0
3. In paragraphs (e)(3)(i)(C)(1) and (2), removing ``required by 
paragraph (e)(3)(iv)'' and adding in its place ``described in paragraph 
(e)(3)(i)(D)''.
0
4. In paragraph (e)(3)(i)(D), removing ``(e)(3)(iii)'' and adding in 
its place ``(e)(3)(i)(C)''.
0
5. In paragraph (e)(3)(ii), removing ``amount with'' and adding in its 
place ``amount (or, with respect to a lower-tier CFC, a tiered 
extraordinary reduction amount under paragraph (f) of this section) 
with''.
    The additions read as follows:


Sec.  1.245A-5T  Limitation of section 245A deduction and section 
954(c)(6) exception (temporary).

* * * * *
    (c) * * *
    (3) * * *
    (iv) * * * Specified property is also property with respect to 
which a loss was recognized during the disqualified period if the loss 
is properly allocable to income not described in section 
951A(c)(2)(A)(i)(I) through (V) under the principles of section 
954(b)(5) (specified loss). If only a portion of the loss recognized 
with respect to property during the disqualified period is specified 
loss, then a portion of the property is treated as specified property 
in an amount that bears the same ratio to the value of the property as 
the amount of specified loss bears to the total amount of loss 
recognized with respect to such property during the disqualified 
period.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-16630 Filed 8-7-19; 8:45 am]
BILLING CODE 4830-01-P

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