[Federal Register Volume 85, Number 95 (Friday, May 15, 2020)]
[Proposed Rules]
[Pages 29368-29369]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08994]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[REG-105495-19]
RIN 1545-BP21


Guidance Related to the Allocation and Apportionment of 
Deductions and Foreign Taxes, Financial Services Income, Foreign Tax 
Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), 
and Consolidated Groups; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; correction.

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SUMMARY: This document contains a correction to a notice of proposed 
rulemaking (REG-105495-19) that was published in the Federal Register 
on December 17, 2019. The proposed regulations provide guidance 
relating to the allocation and apportionment of deductions and 
creditable foreign taxes, the definition of financial services income, 
foreign tax redeterminations, availability of foreign tax credits under 
the transition tax, and the application of the foreign tax credit 
limitation to consolidated groups.

DATES: Written or electronic comments and requests for a public hearing 
were being accepted and must have been received by February 18, 2020. A 
telephonic public hearing has been scheduled for May 20, 2020.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Jeffrey P. Cowan, (202) 317-4924. Regarding the public hearing Regina 
Johnson at 202-317-5177 or email [email protected].

SUPPLEMENTARY INFORMATION: 

Background

    The proposed regulations that are the subject of this correction 
are under section 861, 904, and 960 of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-105495-19) 
contains errors which may prove to be misleading and need to be 
clarified.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-105495-19) that 
was the subject of FR Doc. 2019-24847, published at 84 FR 69124 
(December 17, 2019), is corrected as follows:
    1. On page 69130, third column, the last line of the first partial 
paragraph,

[[Page 29369]]

the language ``Sec.  1.861-17(d)(4)(v)'' is corrected to read ``Sec.  
1.861-17(d)(4)(i)''.
    2. On page 69134, first column, the second line from the bottom of 
the page the language ``245A(g)'' is corrected to read ``245A(d)''.
    3. On page 69139, third column, the eighth line of the second 
paragraph under the caption ``Applicability Dates'', the language 
``January 1, 2020,'' is corrected to read ``January 1, 2020 (or 
taxpayers that are on the sales method only for the last taxable year 
that begins before January 1, 2020),''.
    4. On page 69139, third column, the 10th line of the second 
paragraph under the caption ``Applicability Dates'', the language 
``consistently'' is corrected to read ``consistently with respect to 
such taxable year and any subsequent year''.


Sec.  1.861-17   [Corrected]

0
5. On page 69156, the third column, in Sec.  1.861-17, the third line 
from the bottom of paragraph (g)(3)(i)(A), the language ``7(b)(1))'' is 
corrected to read ``7(b)(1)(ii)''.
0
6. On page 69157, the first column, in Sec.  1.861-17, in the second 
line of paragraph (g)(3)(ii)(B)(3), the language ``(d)(5)(v)'' is 
corrected to read (d)(4)(v)''.
0
7. On page 69157, the second column, in Sec.  1.861-17, in the seventh 
line from the bottom of paragraph (g)(4)(ii)(A), the language ``354'' 
is corrected to read ``364''.


Sec.  1.960-1   [Corrected]

0
8. On page 69177, the second column, in Sec.  1.960-1, third line from 
the bottom of paragraph (d)(3)(ii)(A), the language ``branch,'' is 
corrected to read ``branch from the foreign branch owner,''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2020-08994 Filed 5-14-20; 8:45 am]
 BILLING CODE 4830-01-P