[Federal Register Volume 76, Number 168 (Tuesday, August 30, 2011)]
[Rules and Regulations]
[Page 53818]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-22064]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9535]
RIN 1545-BK25


Determining the Amount of Taxes Paid for Purposes of the Foreign 
Tax Credit; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final and temporary regulations.

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SUMMARY: This document contains a correction to final and temporary 
regulations (TD 9535), that were published in the Federal Register on 
Monday, July 18, 2011. These regulations provide guidance relating to 
the determination of the amount of taxes paid for purposes of the 
foreign tax credit. These regulations address certain highly structured 
transactions that produce inappropriate foreign tax credit results. The 
regulations affect individuals and corporations that claim direct and 
indirect foreign tax credits.

DATES: This correction is effective August 30, 2011, and is applicable 
beginning July 18, 2011.

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

SUPPLEMENTARY INFORMATION:

Background

    The final and temporary regulations (TD 9535) that is the subject 
of this correction are under section 901 of Internal Revenue Code.

Need for Correction

    As published, TD 9535 contains an error that may prove to be 
misleading and is in need of clarification.

Correction of Publication

    Accordingly July 18, 2011 (76 FR 42038), the publication of the 
final and temporary regulations (TD 9535), that were the subject of FR 
Doc. 2011-17920, is corrected as follows:
    On page 42042, column 3, in the preamble under the caption ``K. 
Effective Date'', line 5, the language, ``or after July 17, 2011.'' is 
corrected to read ``or after July 13, 2011.''.

Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal 
Processing Division, Associate Chief Counsel (Procedure and 
Administration).
[FR Doc. 2011-22064 Filed 8-29-11; 8:45 am]
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