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Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

---
identifier: "/us/fr/2011-22067"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "2011-22067"
section_name: "Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction"
positive_law: false
currency: "2011-08-30"
last_updated: "2011-08-30"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "2011-22067"
document_type: "rule"
publication_date: "2011-08-30"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BK41"
fr_citation: "76 FR 53818"
fr_volume: 76
docket_ids:
  - "REG-126519-11"
fr_action: "Correction to notice of proposed rulemaking by cross-reference to temporary regulations."
---

#  Income, war profits, or excess profits tax paid or accrued.

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

**SUMMARY:**

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations that were published in the *Federal Register* on Monday, July 18, 2011. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results.

**FOR FURTHER INFORMATION CONTACT:**

Jeffrey Cowan, (202) 622-3850 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11) that is the subject of this correction is under section 901 of the Internal Revenue Code.

**Need for Correction**

As published July 18, 2011 (76 FR 42076), the notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11) contains errors that may prove to be misleading and are in need of clarification.

**Correction of Publication**

Accordingly, the notice of proposed rulemaking by cross-reference to temporary regulations (REG-126519-11), that was the subject of FR Doc. 2011-17919, is corrected as follows:

Section 1.901-2 is amended by adding paragraphs (e)(5)(iv)(B)( *1* )( *iii* ) and (h)(3) to read as follows:

§ 1.901-2

(e) * * *

(5) * * *

(iv) * * *

(B) * * *

( *1* ) * * *

( *iii* ) [The text of proposed § 1.901-2(e)(5)(iv)(B)( *1* )( *iii* ) is the same as the text of § 1.901-2T(e)(5)(iv)(B)( *1* )( *iii* ) published elsewhere in this issue of the *Federal Register.* ]

(h) * * *

(3) [The text of proposed § 1.901-2(h)(3) is the same as the text of § 1.901-2T(h)(3) published elsewhere in this issue of the *Federal Register* .]

Treena V. Garrett,

Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration.