[Federal Register Volume 85, Number 155 (Tuesday, August 11, 2020)]
[Proposed Rules]
[Page 48485]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-15857]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-106013-19]
RIN 1545-BP22


Guidance Involving Hybrid Arrangements and the Allocation of 
Deductions Attributable to Certain Disqualified Payments Under 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 that was published in the Federal Register on April 8, 2020. 
The proposed regulations that adjust hybrid deduction accounts to take 
into account earnings and profits of a controlled foreign corporation 
that are included in income by a United States shareholder.

DATES: This correction is effective on August 11, 2020 and is 
applicable beginning April 8, 2020.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations 
under section 951A, Jorge M. Oben at (202) 317-6934; concerning all 
other proposed regulations, Richard F. Owens at (202) 317-6501 (not 
toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    The proposed regulations that are the subject of this correction 
are under section 245A of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed regulations (REG-106013-19) 
contained errors that need to be corrected.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-106013-19) that 
was the subject of FR Doc. 2020-05923, published at 85 FR 19858 (April 
8, 2020), is corrected to read as follows:


Sec.  1.951A-2   [Corrected]

0
1. On page 19872, first column, the fifth line of paragraph (c)(6)(i), 
the language ``allocated or'' is corrected to read ``allocated and''.
0
2. On page 19872, the third line from the bottom of paragraph 
(c)(6)(iv)(A)(2), the language, ``allocated or'' is corrected to read 
``allocated and''.
0
3. On page 19873, third column, the third line of paragraph 
(c)(6)(iv)(B)(2), the language, ``are allocated or'' is corrected to 
read ``are allocated and''.

Martin V. Franks,
Branch Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-15857 Filed 8-10-20; 8:45 am]
BILLING CODE 4830-01-P