[Federal Register Volume 84, Number 153 (Thursday, August 8, 2019)]
[Rules and Regulations]
[Pages 38866-38867]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-16631]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9865]
RIN 1545-BO64


Limitation on Deduction for Dividends Received From Certain 
Foreign Corporations and Amounts Eligible for Section 954 Look-Through 
Exception; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final temporary regulations; correction.

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SUMMARY: This document contains a correction to a Treasury Decision 
9865, which was published in the Federal Register on Tuesday, June 18, 
2019. Treasury Decision 9865 contains temporary regulations under 
section 245A of the Internal Revenue Code (the ``Code'') that limit the 
dividends received from current or former controlled foreign 
corporations.

DATES: Effective date: These regulations are effective August 8, 2019 
and applicable June 18, 2019.

FOR FURTHER INFORMATION CONTACT: Logan M. Kincheloe at (202) 317-6937 
(not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9865) that are the subject of this 
correction are issued under sections 245A, 954, and 6038.

Need for Correction

    As published, the final regulations (TD 9865), contains errors that 
may prove to be misleading and are in need of clarification.

Correction to Publication

    Accordingly, the final regulations (TD 9865), that are the subject 
of FR 2019-12442, in the issue of June 18, 2019, are corrected as 
follows:

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1. On page 28398, in the third column, in the tenth line of the second 
full

[[Page 38867]]

paragraph, ``intangible lowed-taxed'' is corrected to read ``intangible 
low-taxed''.
0
2. On page 28403, in the third column, in the fifth line of the first 
partial paragraph, ``Sec.  1.245A-5T(g)(3)(iv)'' is corrected to read 
``Sec.  1.245A-5T(g)(4)(i)''.
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3. On the same page, in the same column, in the twelfth line of the 
first full paragraph, ``Sec.  1.245A-5T(g)(5)'' is corrected to read 
``Sec.  1.245A-5T(g)(4)(i)''.
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4. On page 28404, in the first column, under the heading ``A. In 
General'', in the second paragraph, ``Explanations of Provisions'' is 
corrected to read ``Explanation of Provisions''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2019-16631 Filed 8-7-19; 8:45 am]
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