[Federal Register Volume 84, Number 153 (Thursday, August 8, 2019)]
[Proposed Rules]
[Pages 38892-38893]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-16632]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-106282-18]
RIN 1545-BP35


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

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SUMMARY: This document contains a correction to notice of proposed 
rulemaking by cross-reference to temporary regulations (REG-106282-18) 
that was published in the Federal Register on Tuesday, June 18, 2019.

DATES: Written or electronic comments and requests for a public hearing 
for the notice of proposed rulemaking by cross-reference to temporary 
regulations at 84 FR 28426, June 18, 2019, are still being accepted and 
must be received by September 16, 2019.

ADDRESSES: Send Submissions to CC:PA:LPD:PR (REG-106282-18), 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-
106282-18), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW, Washington, DC 20224. Alternatively, taxpayers may submit 
comments electronically, via the Federal eRulemaking Portal at http://www.regulations.gov (IRS REG-106282-18).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Logan M. Kincheloe, (202) 317-6937; concerning submission of comments 
and/or requests for a hearing Regina Johnson at (202) 317-6901 (not 
toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    This correction to the notice of proposed rulemaking (REG-106282-
18) that is the subject of this document is issued under sections 245A, 
954, and 6038 of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking by cross-reference 
to temporary regulations (REG-106282-18) contains errors that may prove 
to be misleading and are in need of clarification.

Correction to Publication

    Accordingly, the notice of proposed rulemaking by cross-reference 
to temporary regulations, FR 2019-12441, published at 84 FR 28426, June 
18, 2019, is corrected as follows:

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1. On page 28426, the first column, under the caption SUMMARY, the 
third line from the bottom of the last paragraph, the language 
``controlled foreign that receive certain'' is corrected to read 
``controlled foreign corporations that receive certain''.
0
2. On page 28427, in the first column, under the last line of the 
paragraph before the caption Comments and Request Public Hearing 
section add the following sections:

III. Unfunded Mandates Reform Act

    The assessment of costs and benefits under the Unfunded Mandated 
Reform Act of these proposed regulations are explained in the temporary 
regulations under 245A, 954(c)(6), and 6038 published in 84 FR 28398 
(June 18, 2019).

IV. Executive Order 13132: Federalism

    The assessment of the federalism implications as required under 
Executive Order 13132 of these proposed regulations is explained in the 
temporary regulations under sections 245A, 954(c)(6), and 6038 
published in 84 FR 28398 (June 18, 2019).


Sec.  1.245A-1  [Corrected]

0
3. On page 28427, second column, the amendatory instruction Par, 2, the

[[Page 38893]]

language ``Reserved sections 1.245A-1 through and Sec.  1.245A-5 are 
added to read as follows:'' is corrected to read ``Add and reserve 
Sec. Sec.  1.245A-1 through 1.245A-4 and add Sec.  1.245A-5 to read as 
follows: ''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2019-16632 Filed 8-7-19; 8:45 am]
BILLING CODE 4830-01-P