Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits, 44223 [C1-2019-12437]

Download as PDF 44223 Rules and Regulations Federal Register Vol. 84, No. 164 Friday, August 23, 2019 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most of which are keyed to and codified in the Code of Federal Regulations, which is published under 50 titles pursuant to 44 U.S.C. 1510. The Code of Federal Regulations is sold by the Superintendent of Documents. DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 (ii) B’s pro rata share (60%) of the amount which bears the same ratio to the subpart F income of such corporation for the taxable year ($100x) as the part of such year during which A did not own (within the meaning of section 958(a)) such stock bears to the entire taxable year (146/365) (0.6 × $100x × (146/365)) ................... (iii) Amount of reduction under section 951(a)(2)(B) (lesser of (i) or (ii)) .................................... TABLE 1 TO PARAGRAPH (b)(2)(vi)(B)(2) R’s tested income for Year 1 ........................ Less: Reduction under section 951(a)(2)(A) for period (1–1 through 3–14) during which R is not a controlled foreign corporation ($300x × 73/365) ......................... 24x 15x A’s pro rata share of subpart F income as determined under section 951(a)(2) .......... [TD 9866] 21x 2. On page 29338, Table 1 to paragraph (b)(2)(vi)(B)(1) should appear as follows: RIN 1545–BO54; 1545–BO62 Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits Correction In rule document 2019–12437, appearing on pages 29288 through 29370, in the issue of Friday, June 21, 2019 make the following corrections: 1. On page 29337, Table 1 to paragraph (b)(2)(iv)(B) should appear as follows: TABLE 1 TO PARAGRAPH (b)(2)(iv)(B) M’s subpart F income for Year 1 .................. Less: Reduction under section 951(a)(2)(A) for period (1–1 through 5–26) during which M is not a controlled foreign corporation ($100x × 146/365) ....................... jbell on DSK3GLQ082PROD with RULES TABLE 1 TO PARAGRAPH (b)(2)(iv)(B)—Continued $100x Subpart F income for Year 1 as limited by section 951(a)(2)(A) ................................... A’s pro rata share of subpart F income as determined under section 951(a)(2)(A) (0.6 × $60x) ............................................... Less: Reduction under section 951(a)(2)(B) for dividends received by B during Year 1 with respect to the stock of M acquired by A: (i) Dividend received by B ($15x), multiplied by a fraction ($100x/ $100x), the numerator of which is the subpart F income of such corporation for the taxable year ($100x) and the denominator of which is the sum of the subpart F income and the tested income of such corporation for the taxable year ($100x) ($15x × ($100x/$100x)) ...................... 15x 40x 60x 36x TABLE 1 TO PARAGRAPH (b)(2)(vi)(B)(1) R’s subpart F income for Year 1 ................... Less: Reduction under section 951(a)(2)(A) for period (1–1 through 3–14) during which R is not a controlled foreign corporation ($100x × 73/365) ......................... Subpart F income for Year 1 as limited by section 951(a)(2)(A) ................................... A’s pro rata share of subpart F income as determined under section 951(a)(2)(A) (0.6 × $80x) ............................................... Less: Reduction under section 951(a)(2)(B) for dividends received by B during Year 1 with respect to the stock of R indirectly acquired by A: (i) Dividend received by B ($100x) multiplied by a fraction ($100x/$400x), the numerator of which is the subpart F income of such corporation for the taxable year ($100x) and the denominator of which is the sum of the subpart F income and the tested income of such corporation for the taxable year ($400x) ($100x × ($100x/ $400x)) ..................................... 25x (ii) B’s pro rata share (60%) of the amount which bears the same ratio to the subpart F income of such corporation for the taxable year ($100x) as the part of such year during which A did not own (within the meaning of section 958(a)) such stock bears to the entire taxable year (73/365) (0.6 × $100x × (73/365)) ..................... 12x (iii) Amount of reduction under section 951(a)(2)(B) (lesser of (i) or (ii)) .................................... A’s pro rata share of subpart F income as determined under section 951(a)(2) .......... $100x 20x 80x 48x A’s pro rata share of tested income under section 951A(e)(1) ..................................... 15:55 Aug 22, 2019 Jkt 247001 PO 00000 Frm 00001 Fmt 4700 Sfmt 4700 60x 240x 144x 36x 108x [FR Doc. C1–2019–12437 Filed 8–22–19; 8:45 am] BILLING CODE 1300–01–D DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG–2019–0662] RIN 1625–AA00 Safety Zone; Tennessee River, Kentucky Dam Marina Fireworks, Gilbertsville, KY 12x 36x 3. On the same page, Table 1 to paragraph (b)(2)(vi)(B)(2) should appear as follows: VerDate Sep<11>2014 Tested income for Year 1 as limited by under section 951(a)(2)(A) ........................ A’s pro rata share of tested income as determined under § 1.951A–1(d)(2) (0.6 × $240x) ........................................................ Less: Reduction under section 951(a)(2)(B for dividends received by B during Year 1 with respect to the stock of R indirectly acquired by A: (i) Dividend received by B ($100x) multiplied by a fraction ($300x/$400x), the numerator of which is the tested income of such corporation for the taxable year ($300x) and the denominator of which is the sum of the subpart F income and the tested income of such corporation for the taxable year ($400x) ($100x × ($300x/ $400x)) ..................................... 75x (ii) B’s pro rata share (60%) of the amount which bears the same ratio to the tested income of such corporation for the taxable year ($300x) as the part of such year during which A did not own (within the meaning of section 958(a)) such stock bears to the entire taxable year (73/365) (0.6 × $300x × (73/ 365)) ......................................... 36x (iii) Amount of reduction under section 951(a)(2)(B) (lesser of (i) or (ii)) .................................... $300x Coast Guard, DHS. Temporary final rule. AGENCY: ACTION: The Coast Guard is establishing a temporary safety zone for certain waters of the Tennessee River. SUMMARY: E:\FR\FM\23AUR1.SGM 23AUR1

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[Federal Register Volume 84, Number 164 (Friday, August 23, 2019)]
[Rules and Regulations]
[Page 44223]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: C1-2019-12437]



========================================================================
Rules and Regulations
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains regulatory documents 
having general applicability and legal effect, most of which are keyed 
to and codified in the Code of Federal Regulations, which is published 
under 50 titles pursuant to 44 U.S.C. 1510.

The Code of Federal Regulations is sold by the Superintendent of Documents. 

========================================================================


Federal Register / Vol. 84, No. 164 / Friday, August 23, 2019 / Rules 
and Regulations

[[Page 44223]]



DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9866]
RIN 1545-BO54; 1545-BO62


Guidance Related to Section 951A (Global Intangible Low-Taxed 
Income) and Certain Guidance Related to Foreign Tax Credits

Correction

    In rule document 2019-12437, appearing on pages 29288 through 
29370, in the issue of Friday, June 21, 2019 make the following 
corrections:
    1. On page 29337, Table 1 to paragraph (b)(2)(iv)(B) should appear 
as follows:

                   Table 1 to Paragraph (b)(2)(iv)(B)
 
 
 
M's subpart F income for Year 1.................................   $100x
Less: Reduction under section 951(a)(2)(A) for period (1-1           40x
 through 5-26) during which M is not a controlled foreign
 corporation ($100x x 146/365)..................................
                                                         ---------------
Subpart F income for Year 1 as limited by section 951(a)(2)(A)..     60x
A's pro rata share of subpart F income as determined under           36x
 section 951(a)(2)(A) (0.6 x $60x)..............................
Less: Reduction under section 951(a)(2)(B) for dividends
 received by B during Year 1 with respect to the stock of M
 acquired by A:
  (i) Dividend received by B ($15x), multiplied by a         15x
   fraction ($100x/$100x), the numerator of which is the
   subpart F income of such corporation for the taxable
   year ($100x) and the denominator of which is the sum
   of the subpart F income and the tested income of such
   corporation for the taxable year ($100x) ($15x x
   ($100x/$100x)).......................................
  (ii) B's pro rata share (60%) of the amount which          24x
   bears the same ratio to the subpart F income of such
   corporation for the taxable year ($100x) as the part
   of such year during which A did not own (within the
   meaning of section 958(a)) such stock bears to the
   entire taxable year (146/365) (0.6 x $100x x (146/
   365))................................................
  (iii) Amount of reduction under section 951(a)(2)(B)               15x
   (lesser of (i) or (ii))..............................
                                                                 -------
A's pro rata share of subpart F income as determined under           21x
 section 951(a)(2)..............................................
 

    2. On page 29338, Table 1 to paragraph (b)(2)(vi)(B)(1) should 
appear as follows:

                  Table 1 to paragraph (b)(2)(vi)(B)(1)
 
 
 
R's subpart F income for Year 1.................................   $100x
Less: Reduction under section 951(a)(2)(A) for period (1-1           20x
 through 3-14) during which R is not a controlled foreign
 corporation ($100x x 73/365)...................................
                                                         ---------------
Subpart F income for Year 1 as limited by section 951(a)(2)(A)..     80x
A's pro rata share of subpart F income as determined under           48x
 section 951(a)(2)(A) (0.6 x $80x)..............................
Less: Reduction under section 951(a)(2)(B) for dividends
 received by B during Year 1 with respect to the stock of R
 indirectly acquired by A:
  (i) Dividend received by B ($100x) multiplied by a         25x
   fraction ($100x/$400x), the numerator of which is the
   subpart F income of such corporation for the taxable
   year ($100x) and the denominator of which is the sum
   of the subpart F income and the tested income of such
   corporation for the taxable year ($400x) ($100x x
   ($100x/$400x)).......................................
  (ii) B's pro rata share (60%) of the amount which          12x
   bears the same ratio to the subpart F income of such
   corporation for the taxable year ($100x) as the part
   of such year during which A did not own (within the
   meaning of section 958(a)) such stock bears to the
   entire taxable year (73/365) (0.6 x $100x x (73/365))
  (iii) Amount of reduction under section 951(a)(2)(B)               12x
   (lesser of (i) or (ii))..............................
                                                                 -------
A's pro rata share of subpart F income as determined under           36x
 section 951(a)(2)..............................................
 

    3. On the same page, Table 1 to paragraph (b)(2)(vi)(B)(2) should 
appear as follows:

                  Table 1 to paragraph (b)(2)(vi)(B)(2)
 
 
 
R's tested income for Year 1....................................   $300x
Less: Reduction under section 951(a)(2)(A) for period (1-1           60x
 through 3-14) during which R is not a controlled foreign
 corporation ($300x x 73/365)...................................
                                                         ---------------
Tested income for Year 1 as limited by under section                240x
 951(a)(2)(A)...................................................
A's pro rata share of tested income as determined under Sec.        144x
 1.951A-1(d)(2) (0.6 x $240x)...................................
Less: Reduction under section 951(a)(2)(B for dividends received
 by B during Year 1 with respect to the stock of R indirectly
 acquired by A:
  (i) Dividend received by B ($100x) multiplied by a         75x
   fraction ($300x/$400x), the numerator of which is the
   tested income of such corporation for the taxable
   year ($300x) and the denominator of which is the sum
   of the subpart F income and the tested income of such
   corporation for the taxable year ($400x) ($100x x
   ($300x/$400x)).......................................
  (ii) B's pro rata share (60%) of the amount which          36x
   bears the same ratio to the tested income of such
   corporation for the taxable year ($300x) as the part
   of such year during which A did not own (within the
   meaning of section 958(a)) such stock bears to the
   entire taxable year (73/365) (0.6 x $300x x (73/365))
  (iii) Amount of reduction under section 951(a)(2)(B)               36x
   (lesser of (i) or (ii))..............................
                                                                 -------
A's pro rata share of tested income under section 951A(e)(1)....    108x
 

 [FR Doc. C1-2019-12437 Filed 8-22-19; 8:45 am]
 BILLING CODE 1300-01-D