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