[Federal Register Volume 85, Number 239 (Friday, December 11, 2020)]
[Rules and Regulations]
[Page 79837]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-25374]


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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; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations; correction.

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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 December 11, 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 that are the subject of this correction are 
issued under section 951A of the Code.

Need for Correction

    As published, the final regulations contain errors that need to be 
corrected.

Correction of Publication

    Accordingly, the final regulations (TD 9902) that are the subject 
of FR Doc. 2020-15351, beginning on page 44620 in the issue of July 23, 
2020, are corrected as follows:
    On page 44629, in the first column, the text of footnote 6 is 
corrected to read:
    ``Under currently applicable Sec.  1.951A-1(e)(2), a domestic 
partnership can be a controlling domestic shareholder--for example, for 
purposes of determining which party elects the GILTI high-tax exclusion 
under Sec.  1.951A-2(c)(7)(viii)(A), including potentially for taxable 
years beginning after December 31, 2017, under Sec.  1.951A-7(b), as 
discussed in part VIII of this Summary of Comments and Explanation of 
Revisions.''

Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, 
Legal Processing Division, Associate Chief Counsel, (Procedure and 
Administration).
[FR Doc. 2020-25374 Filed 12-10-20; 8:45 am]
BILLING CODE 4830-01-P