[Federal Register Volume 71, Number 156 (Monday, August 14, 2006)]
[Proposed Rules]
[Page 46416]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E6-13119]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-135866-02]
RIN 1545-BA93


Section 1248 Attribution Principles; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; correction.

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SUMMARY: This document corrects a notice of proposed rulemaking (REG-
135866-02) that was published in the Federal Register on Friday, June 
2, 2006 (71 FR 31985) providing guidance for determining the earnings 
and profits attributable to stock of controlled foreign corporations 
(or former controlled foreign corporations) that are (were) involved in 
certain nonrecognition transactions.

FOR FURTHER INFORMATION CONTACT: Michael Gilman, (202) 622-3850 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The notice of proposed rulemaking (REG-135866-02) that is the 
subject of this correction is under section 1248 of the Internal 
Revenue Code.

Need for Correction

    As published, REG-135866-02 contains errors that may prove to be 
misleading and are in need of clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-135866-02) that 
was the subject of FR Doc. E6-8551 is corrected as follows:

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. On page 31991, instructional Par. 4. is amended by adding a 
new entry at the end of the amendatory instruction to read as follows:
    Adding new paragraph (g).


Sec.  1.1248-1  [Corrected]

    Par. 3. On page 31991, Sec.  1.1248-1 is amended by adding a new 
paragraph (g) to read as follows:


Sec.  1.1248-1  Treatment of gain from certain sales or exchanges of 
stock in certain foreign corporations.

* * * * *
    (g) Effective date. Paragraph (a)(4) and paragraph (a)(5), Example 
4, of this section apply to income inclusions that occur on or after 
the date that paragraph and example are published as final regulations 
in the Federal Register.

Guy Traynor,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E6-13119 Filed 8-11-06; 8:45 am]
BILLING CODE 4830-01-P