[Federal Register Volume 74, Number 182 (Tuesday, September 22, 2009)]
[Rules and Regulations]
[Page 48151]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-22694]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9452]
RIN 1545-BB28


Application of Separate Limitations to Dividends From 
Noncontrolled Section 902 Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final regulations (TD 
9452) that were published in the Federal Register on Thursday, June 11, 
2009, regarding the application of separate foreign tax credit 
limitations to dividends received from noncontrolled section 902 
corporations.

DATES: This correction is effective on September 22, 2009 and is 
applicable in taxable years ending on or after April 20, 2009.

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

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations that are the subject of this document are 
under section 964 of the Internal Revenue Code.

Need for Correction

    As published on Thursday, June 11, 2009 (74 FR 27886), the final 
regulations (TD 9452) 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 1.964-1 is amended by revising the last sentence of 
paragraph (c)(2) and paragraph (c)(4)(i)(D) to read as follows:


Sec.  1.964-1  Determination of the earnings and profits of a foreign 
corporation.

* * * * *
    (c) * * *
    (2) * * * See also Sec. Sec.  1.985-5, 1.985-6, and 1.985-7 
relating to adjustments to earnings and profits of a QBU required when 
the QBU changes its functional currency or begins to use the dollar 
approximate separate transactions method of accounting.
    (4) * * *
    (i) * * *
    (D) Whether the domestic shareholder received the written notice 
required by paragraph (c)(3)(iii) of this section.
* * * * *

LaNita VanDyke,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. E9-22694 Filed 9-21-09; 8:45 am]
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