[Federal Register Volume 85, Number 221 (Monday, November 16, 2020)]
[Rules and Regulations]
[Page 72934]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-24092]


=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9909]
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: Final regulations; correction.

-----------------------------------------------------------------------

SUMMARY: This document contains corrections to the final regulations 
(Treasury Decision 9909) that were published in the Federal Register on 
Thursday, August 27, 2020. Treasury Decision 9909 contained final 
regulations under sections 245A and 954 of the Internal Revenue Code 
(the ``Code'') that limit the deduction for certain dividends received 
by United States persons from foreign corporations under section 245A 
and the exception to subpart F income under section 954(c)(6) for 
certain dividends received by controlled foreign corporations.

DATES: These corrections are effective on November 16, 2020.

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

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9909) that are the subject of this 
correction are issued under sections 245A, 954(c)(6), and 6038 of the 
Internal Revenue Code.

Need for Correction

    As published on August 27, 2020 (85 FR 53068) the final regulations 
(TD 9909) contain errors that need to be corrected.

Correction of Publication

0
Accordingly, the final regulations (TD 9909) that are the subject of FR 
Doc. 2020-18543, appearing on page 53068 in the Federal Register of 
August 27, 2020, are corrected as follows:
    1. On page 53075, third column, removing the second and third 
sentence of the last full paragraph.
    2. On page 53076, first column, the seventh line from the bottom of 
the first full paragraph, after the sentence ending ``See proposed 
Sec.  1.245A-5(e)(3)(i)(C).'', adding the language ``Because the 
determination as to whether there would be an extraordinary reduction 
amount or tiered extraordinary reduction amount greater than zero is 
made without regard to an election to close the taxable year, this 
determination is made without taking into account any elections that 
may be available, or other events that may occur, solely by reason of 
an election to close the taxable year, such as the application of 
section 954(b)(4) to a short taxable year created as a result of the 
election.''
    3. On page 53076, first column, the sixth and seventh lines from 
the bottom of the first full paragraph, the language ``Because the 
election can only'' is corrected to read ``Furthermore, because the 
election to close the taxable year can only''.
    4. On page 53077, the second column, the sixth line from the bottom 
of the first full paragraph, the language ``under sections 7805(b)(2)'' 
is corrected to read ``under section 7805(b)(2)''.
    5. On page 53078, the first column, the seventh line of the second 
full paragraph, the language ``Earning subject'' is corrected to read 
``Earnings subject''.
    6. On page 53082, the third column, the last line of the bottom 
partial paragraph, ``gap period'' is corrected to read ``disqualified 
period''.

Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, 
Legal Processing Division, Associate Chief Counsel, (Procedure and 
Administration).
[FR Doc. 2020-24092 Filed 11-13-20; 8:45 am]
BILLING CODE 4830-01-P