[Federal Register Volume 84, Number 149 (Friday, August 2, 2019)]
[Proposed Rules]
[Page 37807]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-16430]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-101828-19]
RIN 1545-BN80


Guidance Under Section 958 (Rules for Determining Stock 
Ownership) and Section 951A (Global Intangible Low-Taxed Income); 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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SUMMARY: This document contains a correction to a notice of proposed 
rulemaking (REG-101828-19) that was published in the Federal Register 
on June 21, 2019. The proposed regulations provide guidance on the 
treatment of domestic partnerships for purposes of determining amounts 
included in the gross income of their partners with respect to foreign 
corporations.

DATES: Written or electronic comments and requests for a public hearing 
are still being accepted and must be received by September 19, 2019.

ADDRESSES: Send submissions to: Internal Revenue Service, CC:PA:LPD:PR 
(REG-101828-19), Room 5203, Post Office 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-
101828-19), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW, Washington, DC 20024, or sent electronically, via the 
Federal eRulemaking Portal at www.regulations.gov (indicate IRS and 
REG-101828-19).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations 
under Sec. Sec.  1.951-1, 1.956-1, and 1.958-1, Joshua P. Roffenbender 
at (202) 317-6934; concerning the proposed regulations under Sec. Sec.  
1.951A-0, 1.951A-2, 1.951A-7, and 1.954-1, Jorge M. Oben at (202) 317-
6934; concerning the proposed regulations under Sec.  1.1502-51, 
Katherine H. Zhang at (202) 317-6848 or Kevin M. Jacobs at (202) 317-
5332; concerning submissions of comments or requests for a public 
hearing, Regina Johnson at (202) 317-6901 (not toll free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The proposed regulations that are the subject of this correction 
are under section 951A of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed regulations (REG-101828-19) 
contains errors which may prove to be misleading and need to be 
clarified.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-101828-19) that 
was the subject of FR Doc. 2019-12436, published at 84 FR 29114 (June 
21, 2019), is corrected to read as follows:


Sec.  1.951A-2  [Corrected]

0
On page 29129, second column, the third line of paragraph (c)(6)(i), 
the language ``951 A(c)(2)(A)(i)(II)'' is corrected to read 
``951A(c)(2)(A)(i)(III)''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-16430 Filed 8-1-19; 8:45 am]
BILLING CODE 4830-01-P