Foreign Tax Credit Guidance Related to the Tax Cuts and Jobs Act, Overall Foreign Loss Recapture, and Foreign Tax Redeterminations; Correcting Amendment, 29323 [2020-08995]
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29323
Rules and Regulations
Federal Register
Vol. 85, No. 95
Friday, May 15, 2020
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.
Correction of Publication
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
DEPARTMENT OF THE TREASURY
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.861–8 is amended by
revising the second and third sentence
in paragraph (c)(4) and revising the first
sentence in paragraph (e)(6)(i) to read as
follows:
■
Internal Revenue Service
26 CFR Part 1
[TD 9882]
RIN 1545–BP19; 1545–BK55; 1545–AC09
Foreign Tax Credit Guidance Related
to the Tax Cuts and Jobs Act, Overall
Foreign Loss Recapture, and Foreign
Tax Redeterminations; Correcting
Amendment
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
AGENCY:
This document contains
corrections to Treasury Decision 9882,
which was published in the Federal
Register on Tuesday, December 17,
2019. Treasury Decision 9882 contained
final and temporary regulations that
provide guidance relating to the
determination of the foreign tax credit
under the Internal Revenue Code.
DATES: These corrections are effective
on May 15, 2020 and applicable
December 17, 2019.
FOR FURTHER INFORMATION CONTACT:
Jeffrey P. Cowan, (202) 317–4924 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
Background
The final regulations (TD 9882) that
are the subject of this correction are
under sections 861 and 904 of the
Internal Revenue Code.
jbell on DSKJLSW7X2PROD with RULES
Need for Correction
As published December 17, 2019 (84
FR 69022), the final and temporary
regulations (TD 9882; FR Doc. 2019–
24848) contained errors that need to be
corrected.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
VerDate Sep<11>2014
16:12 May 14, 2020
Jkt 250001
amended return) either for all taxable
years beginning after December 31,
2017, and before January 1, 2020, or for
its last taxable year beginning before
January 1, 2020, without the prior
consent of the Commissioner. * * *
*
*
*
*
*
§ 1.904–4
[Amended]
Par. 4. Section 1.904–4(c)(6)(iii) is
amended by removing the language
‘‘deemed paid or accrued’’ and adding
the language ‘‘deemed paid’’ in its
place.
■
§ 1.904–5
[Amended]
Par. 5. Section 1.904–5 is amended by
removing paragraph (c)(1)(ii).
■
§ 1.861–8 Computation of taxable income
from sources within the United States and
from other sources and activities
§ 1.904(g)–0
*
■
*
*
*
*
(c) * * *
(4) * * * In determining whether two
or more corporations are members of the
same controlled group under section
267(b)(3), a person is considered to own
stock owned directly by such person,
stock owned by application of section
1563(e)(1), and stock owned by
application of section 267(c). In
determining whether a corporation is
related to a partnership under section
267(b)(10), a person is considered to
own the partnership interest owned
directly by such person and the
partnership interest owned by
application of section 267(e)(3).
*
*
*
*
*
(e) * * *
(6) * * *
(i) * * * The deduction for foreign
income, war profits and excess profits
taxes allowed by section 164 (including
with respect to a controlled foreign
corporation) is allocated and
apportioned among the applicable
statutory and residual groupings under
the principles of § 1.904–6(a)(1)(i), (ii),
and (iv). * * *
*
*
*
*
*
■ Par. 3. Section 1.861–17 is amended
by revising the first sentence in
paragraph (e)(3) to read as follows:
§ 1.861–17 Allocation and apportionment
of research and experimental expenditures.
*
*
*
*
*
(e) * * *
(3) * * * A taxpayer otherwise
subject to the binding election described
in paragraph (e)(1) of this section may
change its method (on an original or an
PO 00000
Frm 00001
Fmt 4700
Sfmt 4700
[Amended]
Par. 6. Section 1.904(g)–0 is amended
by adding ‘‘the’’ in the heading for
§ 1.904(g)–3 before the word
‘‘recapture’’.
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2020–08995 Filed 5–14–20; 8:45 am]
BILLING CODE 4830–01–P
PENSION BENEFIT GUARANTY
CORPORATION
29 CFR Part 4022
Benefits Payable in Terminated SingleEmployer Plans; Interest Assumptions
for Paying Benefits
Pension Benefit Guaranty
Corporation.
ACTION: Final rule.
AGENCY:
This final rule amends the
Pension Benefit Guaranty Corporation’s
regulation on Benefits Payable in
Terminated Single-Employer Plans to
prescribe certain interest assumptions
under the regulation for plans with
valuation dates in June 2020. These
interest assumptions are used for paying
certain benefits under terminating
single-employer plans covered by the
pension insurance system administered
by PBGC.
DATES: Effective June 1, 2020.
FOR FURTHER INFORMATION CONTACT:
Gregory Katz (katz.gregory@pbgc.gov),
Attorney, Regulatory Affairs Division,
Pension Benefit Guaranty Corporation,
SUMMARY:
E:\FR\FM\15MYR1.SGM
15MYR1
Agencies
[Federal Register Volume 85, Number 95 (Friday, May 15, 2020)]
[Rules and Regulations]
[Page 29323]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08995]
========================================================================
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. 85, No. 95 / Friday, May 15, 2020 / Rules and
Regulations
[[Page 29323]]
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9882]
RIN 1545-BP19; 1545-BK55; 1545-AC09
Foreign Tax Credit Guidance Related to the Tax Cuts and Jobs Act,
Overall Foreign Loss Recapture, and Foreign Tax Redeterminations;
Correcting Amendment
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendments.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to Treasury Decision 9882,
which was published in the Federal Register on Tuesday, December 17,
2019. Treasury Decision 9882 contained final and temporary regulations
that provide guidance relating to the determination of the foreign tax
credit under the Internal Revenue Code.
DATES: These corrections are effective on May 15, 2020 and applicable
December 17, 2019.
FOR FURTHER INFORMATION CONTACT: Jeffrey P. Cowan, (202) 317-4924 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9882) that are the subject of this
correction are under sections 861 and 904 of the Internal Revenue Code.
Need for Correction
As published December 17, 2019 (84 FR 69022), the final and
temporary regulations (TD 9882; FR Doc. 2019-24848) contained errors
that 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 for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
0
Par. 2. Section 1.861-8 is amended by revising the second and third
sentence in paragraph (c)(4) and revising the first sentence in
paragraph (e)(6)(i) to read as follows:
Sec. 1.861-8 Computation of taxable income from sources within the
United States and from other sources and activities
* * * * *
(c) * * *
(4) * * * In determining whether two or more corporations are
members of the same controlled group under section 267(b)(3), a person
is considered to own stock owned directly by such person, stock owned
by application of section 1563(e)(1), and stock owned by application of
section 267(c). In determining whether a corporation is related to a
partnership under section 267(b)(10), a person is considered to own the
partnership interest owned directly by such person and the partnership
interest owned by application of section 267(e)(3).
* * * * *
(e) * * *
(6) * * *
(i) * * * The deduction for foreign income, war profits and excess
profits taxes allowed by section 164 (including with respect to a
controlled foreign corporation) is allocated and apportioned among the
applicable statutory and residual groupings under the principles of
Sec. 1.904-6(a)(1)(i), (ii), and (iv). * * *
* * * * *
0
Par. 3. Section 1.861-17 is amended by revising the first sentence in
paragraph (e)(3) to read as follows:
Sec. 1.861-17 Allocation and apportionment of research and
experimental expenditures.
* * * * *
(e) * * *
(3) * * * A taxpayer otherwise subject to the binding election
described in paragraph (e)(1) of this section may change its method (on
an original or an amended return) either for all taxable years
beginning after December 31, 2017, and before January 1, 2020, or for
its last taxable year beginning before January 1, 2020, without the
prior consent of the Commissioner. * * *
* * * * *
Sec. 1.904-4 [Amended]
0
Par. 4. Section 1.904-4(c)(6)(iii) is amended by removing the language
``deemed paid or accrued'' and adding the language ``deemed paid'' in
its place.
Sec. 1.904-5 [Amended]
0
Par. 5. Section 1.904-5 is amended by removing paragraph (c)(1)(ii).
Sec. 1.904(g)-0 [Amended]
0
Par. 6. Section 1.904(g)-0 is amended by adding ``the'' in the heading
for Sec. 1.904(g)-3 before the word ``recapture''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-08995 Filed 5-14-20; 8:45 am]
BILLING CODE 4830-01-P