[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: 2011-22067]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-126519-11]
RIN 1545-BK41


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

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking by cross-reference 
to temporary regulations.

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SUMMARY: This document contains corrections to a notice of proposed 
rulemaking by cross-reference to temporary regulations that were 
published in the Federal Register on Monday, July 18, 2011. These 
regulations address certain highly structured arrangements that produce 
inappropriate foreign tax credit results.

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

SUPPLEMENTARY INFORMATION:

Background

    The notice of proposed rulemaking by cross-reference to temporary 
regulations (REG-126519-11) that is the subject of this correction is 
under section 901 of the Internal Revenue Code.

Need for Correction

    As published July 18, 2011 (76 FR 42076), the notice of proposed 
rulemaking by cross-reference to temporary regulations (REG-126519-11) 
contains errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking by cross-reference 
to temporary regulations (REG-126519-11), that was the subject of FR 
Doc. 2011-17919, is corrected as follows:
    Section 1.901-2 is amended by adding paragraphs 
(e)(5)(iv)(B)(1)(iii) and (h)(3) to read as follows:


Sec.  1.901-2  Income, war profits, or excess profits tax paid or 
accrued.

* * * * *
    (e) * * *
    (5) * * *
    (iv) * * *
    (B) * * *
    (1) * * *
    (iii) [The text of proposed Sec.  1.901-2(e)(5)(iv)(B)(1)(iii) is 
the same as the text of Sec.  1.901-2T(e)(5)(iv)(B)(1)(iii) published 
elsewhere in this issue of the Federal Register.]
* * * * *
    (h) * * *
    (3) [The text of proposed Sec.  1.901-2(h)(3) is the same as the 
text of Sec.  1.901-2T(h)(3) published elsewhere in this issue of the 
Federal Register.]

Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal 
Processing Division, Associate Chief Counsel, Procedure and 
Administration.
[FR Doc. 2011-22067 Filed 8-29-11; 8:45 am]
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