# [Corrected]
**AGENCY:**
Internal Revenue Service (IRS), Treasury.
**ACTION:**
Correcting amendment.
**SUMMARY:**
This document contains correction to final regulations (TD 9273) that were published in the *Federal Register* on Tuesday, August 8, 2006(71 FR 44887) addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is described in both section 367(b) and section 381 of the Internal Revenue Code (Code).
**DATES:**
The correction is effective August 8, 2006.
**FOR FURTHER INFORMATION CONTACT:**
Jeffrey L. Parry, (202) 622-3850 (not a toll-free number).
**SUPPLEMENTARY INFORMATION:**
**Background**
The correction notice that is the subject of this document is under sections 367(b) and 381 of the Internal Revenue Code.
**Need for Correction**
As published, final regulations (TD 9273) contain an error that may prove to be misleading and are in need of clarification.
**Correction of Publication**
**List of Subjects in 26 CFR Part 1**
Income taxes, Reporting and recordkeeping requirements.
**26 CFR Part 1**
**Correction of Publication**
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
**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**
§ 1.367(b)-7
Section 1.367(b)-7(e)(2) *Example 4.* (iii)(C) in the following table under the heading “Foreign taxes” the third column heading “Taxes avaialable” is corrected to read “Foreign taxes available”.
Guy R. Traynor,
Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).