United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2006_register executive 2010-09-22 article Part V Rules and Regulations D09002ee1c80f8a2e D09002ee1c80f8b44 United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains temporary regulations regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations under section 904(d)(4). Section 403 of the American Jobs Creation Act of 2004, Public Law 108-357, 118 Stat. 1418 (October 22, 2004) (AJCA), modified the treatment of such dividends effective for taxable years beginning after December 31, 2002. Section 403(l) of the Gulf Opportunity Zone Act of 2005, Public Law 109-135, 119 Stat. 2577 (December 22, 2005) (GOZA), permits taxpayers to elect to defer the effective date of the AJCA amendments until taxable years beginning after December 31, 2004. The temporary regulations provide guidance needed to comply with these changes and affect corporations claiming foreign tax credits. The text of these temporary regulations also serves as the text of the proposed regulations (REG-144784-02) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register. 71 FR 24516 https://www.govinfo.gov/app/details/FR-2006-04-25/06-3882 06-3882 fr25ap06-11 RIN 1545-BF46 4830-01-P TD 9260 https://www.govinfo.gov/app/details/FR-2006-04-25/06-3882 https://www.govinfo.gov/content/pkg/FR-2006-04-25/html/06-3882.htm https://www.govinfo.gov/content/pkg/FR-2006-04-25/pdf/06-3882.pdf Income Taxes Reporting and Recordkeeping Requirements 27 p. 24516 24542 71 FR 24516 Title 26 Part 1 26 CFR Part 1 Title 26 Part 602 26 CFR Part 602 RIN 1545-BF46 Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Federal Register Vol. 71, Issue RULE 06-3882 V DEPARTMENT OF THE TREASURY Internal Revenue Service 2006-04-25 TD 9260 4830-01-P 06-3882 Temporary regulations.

This document contains temporary regulations regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations under section 904(d)(4). Section 403 of the American Jobs Creation Act of 2004, Public Law 108-357, 118 Stat. 1418 (October 22, 2004) (AJCA), modified the treatment of such dividends effective for taxable years beginning after December 31, 2002. Section 403(l) of the Gulf Opportunity Zone Act of 2005, Public Law 109-135, 119 Stat. 2577 (December 22, 2005) (GOZA), permits taxpayers to elect to defer the effective date of the AJCA amendments until taxable years beginning after December 31, 2004. The temporary regulations provide guidance needed to comply with these changes and affect corporations claiming foreign tax credits. The text of these temporary regulations also serves as the text of the proposed regulations (REG-144784-02) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register.

Effective Date: These regulations are effective April 25, 2006. For dates of applicability, see Sec. Sec. 1.861-9T(f)(4)(iv), 1.861- 12T(c)(4)(iii), 1.902-1T(g), 1.904-2T(h)(1) and (2), 1.904-4T(c)(2)(i), 1.904-5T(o)(2), 1.904-7T(f)(10), 1.904(f)-12T(g)(5), and 1.964-1T(c)(2) and (c)(6). Ginny Chung (202) 622-3850 (not a toll free call). Income Taxes Reporting and Recordkeeping Requirements Income taxes: Separate limitations application to dividends from noncontrolled section 902 corporations, Vol. 71, no. 79 Office of the Federal Register, National Archives and Records Administration 2006-04-25 continuing daily deposited born digital 704 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2006-04-25 P0b002ee18095ec58 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr25ap06 https://www.govinfo.gov/app/details/FR-2006-04-25 https://www.govinfo.gov/content/pkg/FR-2006-04-25/pdf/FR-2006-04-25.pdf https://www.govinfo.gov/content/pkg/FR-2006-04-25/xml/FR-2006-04-25.xml fdlp 23855 24550 DGPO 2010-09-22 2024-06-06 FR-2006-04-25 machine generated eng FR FR-2006-04-25 71 79