[Federal Register Volume 85, Number 197 (Friday, October 9, 2020)]
[Rules and Regulations]
[Page 64040]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-20419]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9902]
RIN 1545-BP15


Guidance Under Sections 951A and 954 Regarding Income Subject to 
a High Rate of Foreign Tax; Correcting Amendment

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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SUMMARY: This document contains corrections to Treasury Decision 9902, 
which was published in the Federal Register on Thursday, July 23, 2020. 
Treasury Decision 9902 contained final regulations under the global 
intangible low-taxed income and subpart F income provisions of the 
Internal Revenue Code regarding the treatment of income that is subject 
to a high rate of foreign tax.

DATES: This correction is effective on October 9, 2020.

FOR FURTHER INFORMATION CONTACT: Jorge M. Oben or Larry R. Pounders at 
(202) 317-6934 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9902) that are the subject of this 
correction are issued under section 951A of the Code.

Need for Correction

    As published, the final regulations (TD 9902) contain errors that 
need to be corrected.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *


0
Par. 2. Section 1.951A-2 is amended by adding a sentence at the end of 
paragraph (c)(7)(viii)(E)(2)(ii) to read as follows:


Sec.  1.951A-2  Tested Income and tested loss.

* * * * *
    (c) * * *
    (7) * * *
    (viii) * * *
    (E) * * *
    (2) * * *
    (ii) * * * Notwithstanding the rule set forth in this paragraph 
(c)(7)(viii)(E)(2)(ii), a controlled foreign corporation is not a 
member of a CFC group if, as of the close of its CFC inclusion year, 
the controlled foreign corporation does not have a controlling domestic 
shareholder.

Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, 
Legal Processing Division, Associate Chief Counsel (Procedure and 
Administration).
[FR Doc. 2020-20419 Filed 10-8-20; 8:45 am]
BILLING CODE 4830-01-P