[Federal Register Volume 71, Number 235 (Thursday, December 7, 2006)]
[Rules and Regulations]
[Page 70877]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E6-20722]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9292]
RIN 1545-BB11


Partner's Distributive Share: Foreign Tax Expenditures; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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SUMMARY: This document contains correction to final regulations (TD 
9292) that were published in the Federal Register on Thursday, October 
19, 2006 (71 FR 61648) regarding the allocation of creditable foreign 
tax expenditures by partnerships.

DATES: The correction is effective October 19, 2006.

FOR FURTHER INFORMATION CONTACT: Timothy J. Leska, (202) 622-3050 or 
Michael I. Gilman (202) 622-3850 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The correction notice that is the subject of this document is under 
section 704 of the Internal Revenue Code.

Need for Correction

    As published, final regulations (TD 9292) contain 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

0
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 1.704-1 is amended by revising instructional Par. 2, 
number 2 to read as follows:
    1. * * *
    2. The heading and text of paragraphs (b)(1)(ii)(b), and (b)(5) 
Examples 25 through 27 are revised.
* * * * *

0
Par. 3. Section 1.704-1(d)(5) is amended by revising Example 25 
paragraph (ii), the ninth sentence and Example 26 paragraph (ii), the 
eighth sentence to read as follows:


Sec.  1.704-1  Partner's distributive share.

* * * * *

    Example 25. * * *
    (ii) * * * Accordingly, the country X taxes will be reallocated 
according to the partners' interests in the partnership.
    Example 26. * * *
    (ii) * * * Because AB's partnership agreement allocates the 
$80,000 of country X taxes and $40,000 of country Y taxes in 
proportion to the distributive shares of income to which such taxes 
relate, the allocations are deemed to be in accordance with the 
partners' interests in the partnership under paragraph (b)(4)(viii) 
of this section.
* * * * *

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
 [FR Doc. E6-20722 Filed 12-6-06; 8:45 am]
BILLING CODE 4830-01-P