Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A; Correction, 54367-54368 [2021-21175]
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Federal Register / Vol. 86, No. 188 / Friday, October 1, 2021 / Rules and Regulations
§ 90.101
[Reserved]
issued under sections 861, 881, 904, and
905 of the Internal Revenue Code.
Bryan Newland,
Assistant Secretary—Indian Affairs.
Need for Correction
[FR Doc. 2021–21385 Filed 9–30–21; 8:45 am]
As published on Thursday, November
12, 2020 (85 FR 71998), the final
regulations (TD 9922) contain errors that
need to be corrected.
BILLING CODE 4337–15–P
DEPARTMENT OF THE TREASURY
List of Subjects in 26 CFR Part 1
Internal Revenue Service
Income taxes, Reporting and
recordkeeping requirements.
26 CFR Part 1
RIN 1545–BP21; 1545–BP22
Guidance Related to the Allocation and
Apportionment of Deductions and
Foreign Taxes, Foreign Tax
Redeterminations, Foreign Tax Credit
Disallowance Under Section 965(g),
Consolidated Groups, Hybrid
Arrangements and Certain Payments
Under Section 951A; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
AGENCY:
This document contains
corrections to the final regulations
(Treasury Decision 9922) that were
published in the Federal Register on
Thursday, November 12, 2020. Treasury
Decision 9922 provided guidance
relating to the allocation and
apportionment of deductions and
creditable foreign taxes, the definition of
financial services income, foreign tax
redeterminations, availability of foreign
tax credits under the transition tax, the
application of the foreign tax credit
limitation to consolidated groups,
adjustments to hybrid deduction
accounts to take into account certain
inclusions in income by a United States
shareholder, conduit financing
arrangements involving hybrid
instruments, and the treatment of
certain payments under the global
intangible low-taxed income provisions.
DATES: Effective on October 1, 2021, and
applicable as of November 12, 2020.
FOR FURTHER INFORMATION CONTACT:
Concerning §§ 1.861–8 and 1.861–17,
Jeffrey P. Cowan, (202) 317–4924;
concerning §§ 1.861–20, 1.904–4, and
1.904–6, Suzanne M. Walsh, (202) 317–
4908; concerning § 1.881–3, Richard F.
Owens, (202) 317–6501; concerning
§ 1.904(g)-3, Jeffrey L. Parry, (202) 317
4916; concerning § 1.905–4T, Corina
Braun, (202) 317–5004 (not toll-free
numbers).
SUMMARY:
Background
The final regulations (TD 9922) that
are the subject of this correction are
VerDate Sep<11>2014
16:40 Sep 30, 2021
Jkt 256001
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:
■
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.861–8 is amended by
revising the last sentence of paragraph
(e)(5)(ii) and the first and second
sentences of paragraph (e)(8)(ii) to read
as follows:
■
§ 1.861–8 Computation of taxable income
from sources within the United States and
from other sources and activities.
*
*
*
*
*
(e) * * *
(5) * * *
(ii) * * * The deductions are
apportioned among the statutory and
residual groupings on the basis of the
relative values (as determined under the
asset method in § 1.861–9 for purposes
of allocating and apportioning the
taxpayer’s interest expense) of the assets
that were involved in the event or (if the
taxpayer no longer owns the assets
involved in the event) the assets that are
used to produce or sell products or
services in the relevant class in each
grouping; such values are determined in
the year the deductions are allowed.
*
*
*
*
*
(8) * * *
(ii) * * * A net operating loss taken
as a deduction in computing taxable
income for a particular taxable year as
allowed under section 172 is allocated
and apportioned to statutory and
residual groupings by reference to the
statutory and residual groupings of the
components of the net operating loss (as
determined under paragraph (e)(8)(i) of
this section) that is deducted in the
taxable year. Except as provided under
the rules for an operative section, if the
full net operating loss carryover is not
taken as a deduction in a taxable year,
the partial net operating loss deduction
is treated as ratably comprising the
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Fmt 4700
Sfmt 4700
components of a net operating loss.
* * *
*
*
*
*
*
■ Par. 3. Section 1.861–17 is amended
in paragraph (d)(4)(iv), by revising the
first sentence and adding a sentence at
the end of the paragraph to read as
follows:
§ 1.861–17 Allocation and apportionment
of research and experimental expenditures.
*
Correction of Publication
[TD 9922]
54367
*
*
*
*
(d) * * *
(4) * * *
(iv) * * * If the controlled party has
entered into a cost sharing arrangement,
in accordance with the provisions of
§ 1.482–7, with the taxpayer for the
purpose of developing intangible
property, then ordinarily the controlled
party is not reasonably expected to
acquire rights in intangible property that
would arise from the taxpayer’s share of
the R&E expenditures with respect to
the cost shared intangibles as defined in
§ 1.482–7(j)(1)(i); acquire products in
which such intangible property is
embedded or used in connection with
the manufacture or sale of such
products; or receive services that
incorporate or directly or indirectly
benefit from such intangible property.
* * * However, the rule in this
paragraph (d)(4)(iv) does not apply, and
the controlled party’s sales are taken
into account, to the extent the taxpayer
licenses, or has licensed, to the
controlled party intangible property
resulting from a cost sharing
arrangement with the controlled party.
*
*
*
*
*
■ Par. 4. Section 1.861–20 is amended
by revising the first sentence of
paragraph (d)(3)(i)(B)(2) to read as
follows:
§ 1.861–20 Allocation and apportionment
of foreign income taxes.
*
*
*
*
*
(d) * * *
(3) * * *
(i) * * *
(B) * * *
(2) * * * The foreign dividend
amount is, to the extent of the U.S.
dividend amount, assigned to the same
statutory and residual grouping (or
ratably to the groupings) to which a
distribution of the U.S. dividend
amount is assigned under Federal
income tax law. * * *
*
*
*
*
*
§ 1.881–3
[Amended]
■ Par. 5. For each entry in § 1.881–3 in
the ‘‘Paragraph Heading’’ column,
remove the language in ‘‘Remove’’
column and add in its place the
E:\FR\FM\01OCR1.SGM
01OCR1
54368
Federal Register / Vol. 86, No. 188 / Friday, October 1, 2021 / Rules and Regulations
language in the ‘‘Add’’ column as set
forth below:
Paragraph heading
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
Paragraph
§ 1.904–4
(e)(5) .........
(e)(6) .........
(e)(7) .........
(e)(8) .........
(e)(9) .........
(e)(10) .......
(e)(11) .......
(e)(12) .......
(e)(13) .......
(e)(14) .......
(e)(15) .......
(e)(16) .......
(e)(17) .......
(e)(18) .......
(e)(19) .......
(e)(20) .......
(e)(21) .......
(e)(22) .......
(e)(23) .......
(e)(24) .......
(e)(25) .......
(e)(26) .......
(e)(27) .......
Remove
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Add
4 ..
5 ..
6 ..
7 ..
8 ..
9 ..
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
Example
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
[Amended]
Par. 6. Section 1.904–4 is amended by
removing the language ‘‘and (3)’’ from
paragraph (q)(1).
■ Par. 7. Section 1.904–6 is amended by
revising the first and second sentences
of paragraph (f) to read as follows:
■
§ 1.904–6 Allocation and apportionment of
foreign income taxes.
*
*
*
*
*
(f) * * * Some or all of the foreign
gross income of a United States
shareholder of a controlled foreign
corporation, or of a U.S. person that
owns the United States shareholder (the
‘‘U.S. owner’’), that is attributable to
foreign law inclusion regime income
with respect to a foreign law CFC
described in § 1.861–20(d)(3)(iii) or
foreign law pass-through income from a
reverse hybrid described in § 1.861–
20(d)(3)(i)(C) is assigned to the section
951A category if, were the controlled
foreign corporation the taxpayer that
recognizes the foreign gross income, the
foreign gross income would be assigned
to the controlled foreign corporation’s
tested income group (as defined in
§ 1.960–1(b)(33)) within the general
category to which an inclusion under
section 951A is attributable. The
amount of the United States
shareholder’s, or the U.S. owner’s,
foreign gross income that is assigned to
the section 951A category (or a specified
separate category associated with the
section 951A category) is based on the
inclusion percentage (as defined in
§ 1.960–2(c)(2)) of the United States
shareholder. * * *
*
*
*
*
*
■ Par. 8. Section 1.904(g)–3 is amended
by revising paragraphs (b)(2) and (3) to
read as follows:
VerDate Sep<11>2014
16:40 Sep 30, 2021
Jkt 256001
§ 1.904 (g)–3 Ordering rules for the
allocation of net operating losses, net
capital losses, U.S. source losses, and
separate limitation losses, and for the
recapture of separate limitation losses,
overall foreign losses, and overall domestic
losses.
*
*
*
*
*
(b) * * *
(2) Full net operating loss deduction.
If the full net operating loss (that
remains after carryovers to other taxable
years) is deducted in computing the
taxable income in a particular year
(carryover year), so that there is no
remaining net operating loss that can be
carried to other taxable years, U.S.
source losses and foreign source losses
in separate categories that comprise the
net operating loss shall be combined
with the U.S. source income or loss and
the foreign source income or loss in the
same separate categories in the
carryover year.
(3) Partial net operating loss
deduction. If the full net operating loss
(that remains after carryovers to other
taxable years) is not deducted in
computing the taxable income in a
carryover year, so that there is
remaining loss that can be carried to
other taxable years, the following rules
apply:
(i) Any U.S. source loss (not to exceed
the amount of the net operating loss
carryover deducted in computing the
taxable income in the carryover year
(the net operating loss deduction)) shall
be carried over to the extent of any U.S.
source income in the carryover year.
(ii) If the net operating loss deduction
exceeds the U.S. source loss carryover
determined under paragraph (b)(3)(i) of
this section, then separate limitation
losses that are part of the net operating
loss shall be tentatively carried over to
the extent of separate limitation income
in the same separate category in the
carryover year. If the sum of the
potential separate limitation loss
carryovers determined under the
preceding sentence exceeds the amount
of the net operating loss deduction
reduced by any U.S. source loss carried
over under paragraph (b)(3)(i) of this
section, then the potential separate
limitation loss carryovers shall be
reduced pro rata so that their sum
equals such amount.
(iii) If the net operating loss deduction
exceeds the sum of the U.S. and
separate limitation loss carryovers
determined under paragraphs (b)(3)(i)
and (ii) of this section, then a
proportionate part of the remaining loss
from each separate category shall be
carried over to the extent of such excess
and combined with the foreign source
PO 00000
Frm 00030
Fmt 4700
Sfmt 4700
loss, if any, in the same separate
categories in the carryover year.
(iv) If the net operating loss deduction
exceeds the sum of all the loss
carryovers determined under paragraphs
(b)(3)(i), (ii), and (iii) of this section,
then any U.S. source loss not carried
over under paragraph (b)(3)(i) of this
section shall be carried over to the
extent of such excess and combined
with the U.S. source loss, if any, in the
carryover year.
*
*
*
*
*
§ 1.905–4T
■
[Removed]
Par. 9. Section 1.905–4T is removed.
Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2021–21175 Filed 9–30–21; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF JUSTICE
28 CFR Part 16
[CPCLO Order No. 009–2021]
Privacy Act of 1974; Implementation
Office of Legal Policy, United
States Department of Justice.
ACTION: Final rule.
AGENCY:
The United States Department
of Justice (DOJ or Department), is
finalizing with changes its Privacy Act
exemption regulations for the system of
records titled, ‘‘Judicial Nominations
Files,’’ JUSTICE/OLP–002, which were
published as a notice of proposed
rulemaking (NPRM) on July 23, 2021.
Specifically, the Department’s
regulations will exempt the records
maintained in JUSTICE/OLP–002 from
one or more provisions of the Privacy
Act.
SUMMARY:
This final rule is effective
November 1, 2021.
DATES:
FOR FURTHER INFORMATION CONTACT:
Matrina Matthews, Executive Officer,
Office of Legal Policy, U.S. Department
of Justice, 950 Pennsylvania Avenue
NW, Room 4234, Washington, DC
20530–0001; telephone: (202) 616–0040;
email: matrina.matthews@usdoj.gov.
SUPPLEMENTARY INFORMATION:
Background
On July 14, 2021, the Office of Legal
Policy (OLP) published in the Federal
Register a System of Records Notice
(SORN) for an OLP system of records
titled, ‘‘Judicial Nominations Files,’’
JUSTICE/OLP–002. 86 FR 37192. On
July 23, 2021, the Department published
E:\FR\FM\01OCR1.SGM
01OCR1
]]>Agencies
[Federal Register Volume 86, Number 188 (Friday, October 1, 2021)]
[Rules and Regulations]
[Pages 54367-54368]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-21175]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9922]
RIN 1545-BP21; 1545-BP22
Guidance Related to the Allocation and Apportionment of
Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax
Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid
Arrangements and Certain Payments Under Section 951A; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendments.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to the final regulations
(Treasury Decision 9922) that were published in the Federal Register on
Thursday, November 12, 2020. Treasury Decision 9922 provided guidance
relating to the allocation and apportionment of deductions and
creditable foreign taxes, the definition of financial services income,
foreign tax redeterminations, availability of foreign tax credits under
the transition tax, the application of the foreign tax credit
limitation to consolidated groups, adjustments to hybrid deduction
accounts to take into account certain inclusions in income by a United
States shareholder, conduit financing arrangements involving hybrid
instruments, and the treatment of certain payments under the global
intangible low-taxed income provisions.
DATES: Effective on October 1, 2021, and applicable as of November 12,
2020.
FOR FURTHER INFORMATION CONTACT: Concerning Sec. Sec. 1.861-8 and
1.861-17, Jeffrey P. Cowan, (202) 317-4924; concerning Sec. Sec.
1.861-20, 1.904-4, and 1.904-6, Suzanne M. Walsh, (202) 317-4908;
concerning Sec. 1.881-3, Richard F. Owens, (202) 317-6501; concerning
Sec. 1.904(g)-3, Jeffrey L. Parry, (202) 317 4916; concerning Sec.
1.905-4T, Corina Braun, (202) 317-5004 (not toll-free numbers).
Background
The final regulations (TD 9922) that are the subject of this
correction are issued under sections 861, 881, 904, and 905 of the
Internal Revenue Code.
Need for Correction
As published on Thursday, November 12, 2020 (85 FR 71998), the
final regulations (TD 9922) contain 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 last sentence of
paragraph (e)(5)(ii) and the first and second sentences of paragraph
(e)(8)(ii) to read as follows:
Sec. 1.861-8 Computation of taxable income from sources within the
United States and from other sources and activities.
* * * * *
(e) * * *
(5) * * *
(ii) * * * The deductions are apportioned among the statutory and
residual groupings on the basis of the relative values (as determined
under the asset method in Sec. 1.861-9 for purposes of allocating and
apportioning the taxpayer's interest expense) of the assets that were
involved in the event or (if the taxpayer no longer owns the assets
involved in the event) the assets that are used to produce or sell
products or services in the relevant class in each grouping; such
values are determined in the year the deductions are allowed.
* * * * *
(8) * * *
(ii) * * * A net operating loss taken as a deduction in computing
taxable income for a particular taxable year as allowed under section
172 is allocated and apportioned to statutory and residual groupings by
reference to the statutory and residual groupings of the components of
the net operating loss (as determined under paragraph (e)(8)(i) of this
section) that is deducted in the taxable year. Except as provided under
the rules for an operative section, if the full net operating loss
carryover is not taken as a deduction in a taxable year, the partial
net operating loss deduction is treated as ratably comprising the
components of a net operating loss. * * *
* * * * *
0
Par. 3. Section 1.861-17 is amended in paragraph (d)(4)(iv), by
revising the first sentence and adding a sentence at the end of the
paragraph to read as follows:
Sec. 1.861-17 Allocation and apportionment of research and
experimental expenditures.
* * * * *
(d) * * *
(4) * * *
(iv) * * * If the controlled party has entered into a cost sharing
arrangement, in accordance with the provisions of Sec. 1.482-7, with
the taxpayer for the purpose of developing intangible property, then
ordinarily the controlled party is not reasonably expected to acquire
rights in intangible property that would arise from the taxpayer's
share of the R&E expenditures with respect to the cost shared
intangibles as defined in Sec. 1.482-7(j)(1)(i); acquire products in
which such intangible property is embedded or used in connection with
the manufacture or sale of such products; or receive services that
incorporate or directly or indirectly benefit from such intangible
property. * * * However, the rule in this paragraph (d)(4)(iv) does not
apply, and the controlled party's sales are taken into account, to the
extent the taxpayer licenses, or has licensed, to the controlled party
intangible property resulting from a cost sharing arrangement with the
controlled party.
* * * * *
0
Par. 4. Section 1.861-20 is amended by revising the first sentence of
paragraph (d)(3)(i)(B)(2) to read as follows:
Sec. 1.861-20 Allocation and apportionment of foreign income taxes.
* * * * *
(d) * * *
(3) * * *
(i) * * *
(B) * * *
(2) * * * The foreign dividend amount is, to the extent of the U.S.
dividend amount, assigned to the same statutory and residual grouping
(or ratably to the groupings) to which a distribution of the U.S.
dividend amount is assigned under Federal income tax law. * * *
* * * * *
Sec. 1.881-3 [Amended]
0
Par. 5. For each entry in Sec. 1.881-3 in the ``Paragraph Heading''
column, remove the language in ``Remove'' column and add in its place
the
[[Page 54368]]
language in the ``Add'' column as set forth below:
------------------------------------------------------------------------
Paragraph heading Remove Add
------------------------------------------------------------------------
Paragraph (e)(5)................. Example 4......... Example 5
Paragraph (e)(6)................. Example 5......... Example 6
Paragraph (e)(7)................. Example 6......... Example 7
Paragraph (e)(8)................. Example 7......... Example 8
Paragraph (e)(9)................. Example 8......... Example 9
Paragraph (e)(10)................ Example 9......... Example 10
Paragraph (e)(11)................ Example 10........ Example 11
Paragraph (e)(12)................ Example 11........ Example 12
Paragraph (e)(13)................ Example 12........ Example 13
Paragraph (e)(14)................ Example 13........ Example 14
Paragraph (e)(15)................ Example 14........ Example 15
Paragraph (e)(16)................ Example 15........ Example 16
Paragraph (e)(17)................ Example 16........ Example 17
Paragraph (e)(18)................ Example 17........ Example 18
Paragraph (e)(19)................ Example 18........ Example 19
Paragraph (e)(20)................ Example 19........ Example 20
Paragraph (e)(21)................ Example 20........ Example 21
Paragraph (e)(22)................ Example 21........ Example 22
Paragraph (e)(23)................ Example 22........ Example 23
Paragraph (e)(24)................ Example 23........ Example 24
Paragraph (e)(25)................ Example 24........ Example 25
Paragraph (e)(26)................ Example 25........ Example 26
Paragraph (e)(27)................ Example 26........ Example 27
------------------------------------------------------------------------
Sec. 1.904-4 [Amended]
0
Par. 6. Section 1.904-4 is amended by removing the language ``and (3)''
from paragraph (q)(1).
0
Par. 7. Section 1.904-6 is amended by revising the first and second
sentences of paragraph (f) to read as follows:
Sec. 1.904-6 Allocation and apportionment of foreign income taxes.
* * * * *
(f) * * * Some or all of the foreign gross income of a United
States shareholder of a controlled foreign corporation, or of a U.S.
person that owns the United States shareholder (the ``U.S. owner''),
that is attributable to foreign law inclusion regime income with
respect to a foreign law CFC described in Sec. 1.861-20(d)(3)(iii) or
foreign law pass-through income from a reverse hybrid described in
Sec. 1.861-20(d)(3)(i)(C) is assigned to the section 951A category if,
were the controlled foreign corporation the taxpayer that recognizes
the foreign gross income, the foreign gross income would be assigned to
the controlled foreign corporation's tested income group (as defined in
Sec. 1.960-1(b)(33)) within the general category to which an inclusion
under section 951A is attributable. The amount of the United States
shareholder's, or the U.S. owner's, foreign gross income that is
assigned to the section 951A category (or a specified separate category
associated with the section 951A category) is based on the inclusion
percentage (as defined in Sec. 1.960-2(c)(2)) of the United States
shareholder. * * *
* * * * *
0
Par. 8. Section 1.904(g)-3 is amended by revising paragraphs (b)(2) and
(3) to read as follows:
Sec. 1.904 (g)-3 Ordering rules for the allocation of net operating
losses, net capital losses, U.S. source losses, and separate limitation
losses, and for the recapture of separate limitation losses, overall
foreign losses, and overall domestic losses.
* * * * *
(b) * * *
(2) Full net operating loss deduction. If the full net operating
loss (that remains after carryovers to other taxable years) is deducted
in computing the taxable income in a particular year (carryover year),
so that there is no remaining net operating loss that can be carried to
other taxable years, U.S. source losses and foreign source losses in
separate categories that comprise the net operating loss shall be
combined with the U.S. source income or loss and the foreign source
income or loss in the same separate categories in the carryover year.
(3) Partial net operating loss deduction. If the full net operating
loss (that remains after carryovers to other taxable years) is not
deducted in computing the taxable income in a carryover year, so that
there is remaining loss that can be carried to other taxable years, the
following rules apply:
(i) Any U.S. source loss (not to exceed the amount of the net
operating loss carryover deducted in computing the taxable income in
the carryover year (the net operating loss deduction)) shall be carried
over to the extent of any U.S. source income in the carryover year.
(ii) If the net operating loss deduction exceeds the U.S. source
loss carryover determined under paragraph (b)(3)(i) of this section,
then separate limitation losses that are part of the net operating loss
shall be tentatively carried over to the extent of separate limitation
income in the same separate category in the carryover year. If the sum
of the potential separate limitation loss carryovers determined under
the preceding sentence exceeds the amount of the net operating loss
deduction reduced by any U.S. source loss carried over under paragraph
(b)(3)(i) of this section, then the potential separate limitation loss
carryovers shall be reduced pro rata so that their sum equals such
amount.
(iii) If the net operating loss deduction exceeds the sum of the
U.S. and separate limitation loss carryovers determined under
paragraphs (b)(3)(i) and (ii) of this section, then a proportionate
part of the remaining loss from each separate category shall be carried
over to the extent of such excess and combined with the foreign source
loss, if any, in the same separate categories in the carryover year.
(iv) If the net operating loss deduction exceeds the sum of all the
loss carryovers determined under paragraphs (b)(3)(i), (ii), and (iii)
of this section, then any U.S. source loss not carried over under
paragraph (b)(3)(i) of this section shall be carried over to the extent
of such excess and combined with the U.S. source loss, if any, in the
carryover year.
* * * * *
Sec. 1.905-4T [Removed]
0
Par. 9. Section 1.905-4T is removed.
Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2021-21175 Filed 9-30-21; 8:45 am]
BILLING CODE 4830-01-P
