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Guidance Under Section 951 for Determining Pro Rata Share; Correction

---
identifier: "/us/fr/05-22260"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Guidance Under Section 951 for Determining Pro Rata Share; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "05-22260"
section_name: "Guidance Under Section 951 for Determining Pro Rata Share; Correction"
positive_law: false
currency: "2005-11-09"
last_updated: "2005-11-09"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "05-22260"
document_type: "rule"
publication_date: "2005-11-09"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BD49"
fr_citation: "70 FR 67905"
fr_volume: 70
docket_ids:
  - "TD 9222"
effective_date: "2005-08-25"
fr_action: "Correcting amendment."
---

#  [Corrected]

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document corrects final regulations (TD 9222) that were published in the *Federal Register* on Thursday, August 25, 2005 (70 FR 49864). The final regulations under section 951(a) of the Internal Revenue Code (Code) provide guidance for determining a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations.

**DATES:**

This correction is effective August 25, 2005.

**FOR FURTHER INFORMATION CONTACT:**

Jeffrey L. Vinnik, (202) 622-3840 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final regulations (TD 9222) that are the subject of this correction are under section 951(a) of the Internal Revenue Code.

**Need for Correction**

As published, the final regulations (TD 9222) contain errors that may prove to be misleading and are in need of clarification.

**List of Subjects 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**Correction of Publication**

**26 CFR Part 1**

Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

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

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

§ 1.951-1

1. In § 1.951-1(a), the undesignated paragraph is designated as paragraph (a)(3).

2. Section 1.951-1(e)(6), paragraph (ii) of *Example 5,* sixth sentence, the language “common shareholders by reference to the” is removed and the language “common shares by reference to the” is added in its place.

3. Section 1.951-1(e)(6), paragraph (i) of *Example 7,* sixth sentence, the language “income of United States shareholder under” is removed and the language “income of a United States shareholder under” is added in its place.

4. Section 1.951-1(e)(6), paragraph (i) of *Example 8,* third sentence, the language “Foreign Individual N, a foreign individual.” is removed and the language “Individual N, a foreign individual.” is added in its place.

Cynthia E. Grigsby,

Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).