Determining the Amount of Taxes Paid for Purposes of the

Official source: Federal Register (GovInfo) (https://www.govinfo.gov/content/pkg/FR-2011-08-30/pdf/2011-22066.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

53818 Federal Register / Vol. 76, No. 168 / Tuesday, August 30, 2011 / Rules and Regulations

Monday, July 18, 2011. These regulations provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured transactions that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

DATES: This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations (TD 9535) that is the subject of this correction are under section 901 of Internal Revenue Code.

Need for Correction

As published, TD 9535 contains an error that may prove to be misleading and is in need of clarification.

Correction of Publication

Accordingly July 18, 2011 (76 FR 42038), the publication of the final and temporary regulations (TD 9535), that were the subject of FR Doc. 2011–17920, is corrected as follows:

On page 42042, column 3, in the preamble under the caption ‘‘K. Effective Date’’, line 5, the language, ‘‘or after July 17, 2011.’’ is corrected to read ‘‘or after July 13, 2011.’’.

Treena V. Garrett, Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).

[FR Doc. 2011–22064 Filed 8–29–11; 8:45 am]

BILLING CODE 4830–01–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9536]

RIN 1545–BK40

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final and temporary regulations.

SUMMARY: This document contains a correction to final and temporary regulations (TD 9536) that were

1. Section 543.3 is amended by revising paragraph (c)(3) to read as follows:

§ 543.3 How do tribal governments comply with this part?

- - - (c) * - (3) Establish a deadline, no later than October 12, 2012, by which a gaming operation must come into compliance with the tribal internal control standards. However, the tribal gaming regulatory authority may extend the deadline by six months if written notice citing justification is provided to the Commission no later than two weeks before the deadline.

Dated: August 24, 2011, Washington, DC. Tracie L. Stevens, Chairwoman. Steffani A. Cochran, Vice-Chairwoman. Daniel J. Little, Associate Commissioner.

[FR Doc. 2011–22035 Filed 8–29–11; 8:45 am]

BILLING CODE P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG–126519–11]

RIN 1545–BK41

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

SUMMARY: This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations that were published in the Federal Register on Monday, July 18, 2011. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results.

FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The notice of proposed rulemaking by cross-reference to temporary regulations (REG–126519–11) that is the subject of this correction is under section 901 of the Internal Revenue Code.

Need for Correction

As published July 18, 2011 (76 FR 42076), the notice of proposed rulemaking by cross-reference to temporary regulations (REG–126519–11) contains errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the notice of proposed rulemaking by cross-reference to temporary regulations (REG–126519– 11), that was the subject of FR Doc. 2011–17919, is corrected as follows: Section 1.901–2 is amended by adding paragraphs (e)(5)(iv)(B)( 1 )( iii ) and (h)(3) to read as follows:

§ 1.901–2 Income, war profits, or excess profits tax paid or accrued.

- - - (e) * - (5) * - (iv) * - (B) * - ( 1 ) * - ( iii ) [The text of proposed § 1.901– 2(e)(5)(iv)(B)( 1 )( iii ) is the same as the text of § 1.901–2T(e)(5)(iv)(B)( 1 )( iii ) published elsewhere in this issue of the Federal Register. ]
- - - (h) * - (3) [The text of proposed § 1.901– 2(h)(3) is the same as the text of § 1.901– 2T(h)(3) published elsewhere in this issue of the Federal Register .]

Treena V. Garrett, Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration.

[FR Doc. 2011–22067 Filed 8–29–11; 8:45 am]

BILLING CODE 4830–01–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9535]

RIN 1545–BK25

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final and temporary regulations.

SUMMARY: This document contains a correction to final and temporary regulations (TD 9535), that were published in the Federal Register on

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Federal Register / Vol. 76, No. 168 / Tuesday, August 30, 2011 / Rules and Regulations 53819

published in the Federal Register on Monday, July 18, 2011, providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

DATES: This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary and final regulation (TD 9536) that is the subject of this correction is under section 901 of the Internal Revenue Code.

Need for Correction

As published July 18, 2011 (76 FR 42036), TD 9536 contains an error that may prove to be misleading and is in need of clarification.

Correction of Publication

Accordingly, the publication of the final and temporary regulations (TD 9536), that were the subject of FR Doc. 2011–17916, is corrected as follows: On page 42037, column 2, in the preamble under the caption ‘‘Explanation of Provision’’, first paragraph, tenth line from the bottom, the language, ‘‘2(e)(5)(iv)(B)( 1 )( iii ) that a foreign’’ is corrected to read ‘‘2T(e)(5)(iv)(B)( 1 )( iii ) that a foreign’’.

Treena V. Garrett, Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

[FR Doc. 2011–22066 Filed 8–29–11; 8:45 am]

BILLING CODE 4830–01–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9536]

RIN 1545–BK40

Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

SUMMARY: This document contains amendments to correct errors in final and temporary regulations (TD 9536) that were published in the Federal Register on Monday, July 18, 2011, providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

DATES: This correction is effective on August 30, 2011 and is applicable beginning July 18, 2011.

FOR FURTHER INFORMATION CONTACT: Jeffery Cowan, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary and final regulation (TD 9536) that is the subject of this correction is under section 901 of the Internal Revenue Code.

Need for Correction

As published July 18, 2011 (76 FR 42036), TD 9536 contains errors that may prove to be misleading and is in need of clarification.

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

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

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

Par. 2. Section 1.901–2 is amended by adding paragraphs (e)(5)(iv)(B)( 1 )( iii ) and (h)(3) to read as follows:

§ 1.901–2 Income, war profits, or excess profits tax paid or accrued.

- - - (e) * - (5) * - (iv) * - (B) * - ( 1 ) * - ( iii ) [Reserved]. For further guidance, see § 1.901–2T(e)(5)(iv)(B)( 1 )( iii ).
- - - (h) * - (3) [Reserved]. For further guidance, see § 1.901–2T(h)(3).
Par. 3. Section 1.901–2T is added to read as follows:

§ 1.901–2T Income, war profits, or excess profits tax paid or accrued.

(a) through (e)(5)(iv)(B)( 1 )( ii )

[Reserved]. For further guidance, see § 1.901–2(a) through (e)(5)(iv)(B)( 1 )( ii ).

( iii ) A foreign payment attributable to income of the entity, within the meaning of § 1.901–2(e)(5)(iv)(B)( 1 )( ii ), also includes a withholding tax (within the meaning of section 901(k)(1)(B)) imposed on a dividend or other distribution (including distributions made by a pass-through entity or an entity that is disregarded as an entity separate from its owner for U.S. tax purposes) with respect to the equity of the entity.

( 2 ) through (h)(2) [Reserved]. For further guidance, see § 1.901– 2(e)(5)(iv)(B)( 2 ) through (h)(2). (h)(3) Effective/applicability date. This section applies to foreign payments that, if such payments were an amount of tax paid, would be considered paid or accrued under § 1.901–2(f) on or after July 14, 2011.

(h)(4) Expiration date. The applicability of this section expires on July 14, 2014.

Treena V. Garrett, Federal Register Liaison, Publication and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

[FR Doc. 2011–22065 Filed 8–29–11; 8:45 am]

BILLING CODE 4830–01–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9534]

RIN 1545–BD81

Methods of Accounting Used by Corporations That Acquire the Assets of Other Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document describes corrections to final regulations (TD 9534) relating to the methods of accounting, including the inventory methods, to be used by corporations that acquire the assets of other corporations in certain corporate reorganizations and tax-free liquidations. These regulations were published in the Federal Register on Monday, August 1, 2011.

DATES: This correction is effective on August 31, 2011.

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