[Federal Register Volume 70, Number 216 (Wednesday, November 9, 2005)]
[Rules and Regulations]
[Pages 67905-67906]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 05-22260]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9222]
RIN 1545-BD49


Guidance Under Section 951 for Determining Pro Rata Share; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document corrects final regulations (TD 9222) that were 
published in the Federal Register on Thursday, August 25, 2005 (70 FR 
49864). The final regulations under section 951(a) of the Internal 
Revenue Code (Code) provide guidance for determining a United States 
shareholder's pro rata share of a controlled foreign corporation's 
(CFC's) 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withdrawn from investment in less developed countries, and previously 
excluded subpart F income withdrawn from foreign base company shipping 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.

DATES: This correction is effective August 25, 2005.

FOR FURTHER INFORMATION CONTACT: Jeffrey L. Vinnik, (202) 622-3840 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9222) that are the subject of this 
correction are under section 951(a) of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9222) contain errors that 
may prove to be misleading and are in need of clarification.

List of Subjects 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

[[Page 67906]]

Correction of Publication

0
Accordingly, 26 CFR Part 1 is corrected by making the following 
correcting amendment:

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 * * *


Sec.  1.951-1  [Corrected]

0
1. In Sec.  1.951-1(a), the undesignated paragraph is designated as 
paragraph (a)(3).
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2. Section 1.951-1(e)(6), paragraph (ii) of Example 5, sixth sentence, 
the language ``common shareholders by reference to the'' is removed and 
the language ``common shares by reference to the'' is added in its 
place.
0
3. Section 1.951-1(e)(6), paragraph (i) of Example 7, sixth sentence, 
the language ``income of United States shareholder under'' is removed 
and the language ``income of a United States shareholder under'' is 
added in its place.
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4. Section 1.951-1(e)(6), paragraph (i) of Example 8, third sentence, 
the language ``Foreign Individual N, a foreign individual.'' is removed 
and the language ``Individual N, a foreign individual.'' is added in 
its place.

Cynthia E. Grigsby,
Acting Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 05-22260 Filed 11-8-05; 8:45 am]
BILLING CODE 4830-01-P