[Federal Register Volume 73, Number 56 (Friday, March 21, 2008)]
[Rules and Regulations]
[Page 15063]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-5685]


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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: Correcting amendments

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

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 
amendments:

PART 1--INCOME TAXES

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Paragraph 1. The authority citation for part 1 continues to read, in 
part, as follows:

    Authority: 26 U.S.C. 7805 * * *

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Par. 2. Section 1.904-4 is amended as follows:
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1. In paragraph (h)(4) Example 3, in the first sentence, the language 
``Example (3)'' is removed and the language ``Example 2'' is added in 
its place.
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2. In paragraph (i), in the last sentence, the language ``dividends 
received or accrued by the taxpayer from each separate noncontrolled 
section 902 corporation'' is removed and the language ``income in each 
separate category'' is added in its place.

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Par. 3. Section 1.904-7T(g) is amended as follows:
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3. In paragraph (g)(2), in the last sentence, the language ``Similar 
rules shall apply to characterize any deficits in the pre-2007 pools 
and previously-taxed earnings and profits described in section 
959(c)(1)(A) that are attributable to earnings in the pre-2007 pools.'' 
is removed and the language ``Similar rules shall apply to characterize 
any deficits in the pre-2007 pools and previously-taxed earnings and 
profits described in section 959(c)(1) and (2) that are attributable to 
earnings in the pre-2007 pools.'' is added in its place.
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4. In paragraph (g)(4), in the last sentence, the language ``Similar 
rules shall apply to characterize any deficits or previously-taxed 
earnings and profits described in section 959(c)(1)(A) that are 
attributable to pre-1987 accumulated profits.'' is removed and the 
language ``Similar rules shall apply to characterize any deficits or 
previously-taxed earnings and profits described in section 959(c)(1) 
and (2) that are attributable to pre-1987 accumulated profits.'' is 
added in its place.

LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E8-5685 Filed 3-20-08; 8:45 am]
BILLING CODE 4830-01-P