[Federal Register Volume 73, Number 56 (Friday, March 21, 2008)]
[Rules and Regulations]
[Pages 15063-15064]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-5683]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9368]
RIN 1545-BG55


Reduction of Foreign Tax Credit Limitation Categories Under 
Section 904(d); Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correction.

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SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9368) that were published in the Federal Register on

[[Page 15064]]

Friday, December 21, 2007 (72 FR 72582) regarding the reduction of the 
number of separate foreign tax credit limitation categories under 
section 904(d) of the Internal Revenue Code. These regulations affect 
taxpayers claiming foreign tax credits and provide guidance needed to 
comply with the statutory changes made by the American Jobs Creation 
Act of 2004 (AJCA).

DATES: The correction is effective March 21, 2008.

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

SUPPLEMENTARY INFORMATION: 

Background

    The final and temporary regulations (TD 9368) that are the subject 
of the correction are under section 904 of the Internal Revenue Code.

Need for Correction

    As published, final and temporary regulations (TD 9368) contain 
errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the publication of the final and temporary regulations 
(TD 9368), which were the subject of FR Doc. E7-24782, is corrected as 
follows:
    1. On page 72585, column 1, in the preamble, under the paragraph 
heading ``V. Post-1986 Undistributed Earnings and Post-1986 Foreign 
Income Taxes of a Foreign Corporation as of the End of the 
Corporation's Last Pre-2007 Taxable Year'', second line of the first 
paragraph of the column, the language ``described in section 
959(c)(1)(A),'' is corrected to read ``described in section 959(c)(1) 
and (2),''.
    2. On page 72586, column 3, in the preamble, under the paragraph 
heading ``VI. Separate Limitation Losses and Overall Foreign Losses'', 
first line of the second paragraph of the column, the language 
``Section 1.904-12T(h)(4) provides that'' is corrected to read 
``Section 1.904(f)-12T(h)(4) provides that''.
    3. On page 72586, column 3, in the preamble, under the paragraph 
heading ``VI. Separate Limitation Losses and Overall Foreign Losses'', 
first line of the third paragraph of the column, the language ``Section 
1.904-12T(h)(5) provides that'' is corrected to read ``Section 
1.904(f)-12T(h)(5) provides that''.
    4. On page 72586, column 3, in the preamble, under the paragraph 
heading ``VI. Separate Limitation Losses and Overall Foreign Losses'', 
sixth line of the third paragraph of the column, the language ``rules 
of Sec.  1.904-12T(g)(1) and (2)'' is corrected to read ``rules of 
Sec.  1.904(f)-12T(g)(1) and (2)''.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
 [FR Doc. E8-5683 Filed 3-20-08; 8:45 am]
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