[Federal Register Volume 81, Number 249 (Wednesday, December 28, 2016)]
[Proposed Rules]
[Pages 95541-95542]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-31358]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-114734-16]
RIN 1545-BN51


United States Property Held by Controlled Foreign Corporations 
Through Partnerships With Special Allocations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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SUMMARY: This document contains corrections to a notice of proposed 
rulemaking (REG-114734-16) that was published in the Federal Register 
on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations 
provide rules regarding the

[[Page 95542]]

determination of the amount of the United States property treated as 
held by a controlled foreign corporation (CFC) through a partnership.

DATES: Written or electronic comments and request for a public hearing 
are still being accepted and must be received by February 1, 2017.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-114734-16), Room 
5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
114734-16), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW., Washington, DC, or sent electronically via the Federal 
eRulemaking Portal at http://www.regulations.gov (IRS REG-114734-16).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Rose E. Jenkins, (202) 317-6934; concerning submissions of comments or 
request for a public hearing, Regina Johnson, (202) 317-6901 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The notice of proposed rulemaking (REG-114734-16) that is the 
subject of this document is under sections 954 and 956 of the Internal 
Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-114734-16) 
contains errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking, (REG-114734-16), 
that was the subject of FR Doc. 2016-26424, is corrected as follows:

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1. On page 76543, first column, in the preamble, the sixth line from 
the top of the page, the language, ``property that does not have a 
principal'' is corrected to read ``property that is respected for 
Federal income tax purposes under section 704(b) and the regulations 
thereunder and does not have a principal''.


Sec.  1.956-4  [Corrected]

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2. On page 76543, third column, third line from the bottom of paragraph 
(b)(2)(ii), the language ``allocation does not have a principal'' is 
corrected to read ``allocation will be respected for Federal income tax 
purposes under section 704(b) and the regulations thereunder and does 
not have a principal''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-31358 Filed 12-27-16; 8:45 am]
BILLING CODE 4830-01-P