Bulletin No. 2005-40 October 3, 2005

administration of the cost sharing rules. A public hearing is scheduled for November 16, 2005.

REG–129782–05, page 675. Proposed regulations under section 951 of the Code prescribe rules under which a United States shareholder of a controlled foreign corporation (CFC) determines its pro rata share of the subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations, when a CFC’s earnings and profits for a taxable year substantially exceed its net income under United States generally accepted accounting principles (US GAAP).