# Tested Income and tested loss.
**AGENCY:**
Internal Revenue Service (IRS), Treasury.
**ACTION:**
Correcting amendments.
**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 October 9, 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 (TD 9902) that are the subject of this correction are issued under section 951A of the Code.
**Need for Correction**
As published, the final regulations (TD 9902) contain errors that need to be corrected.
**List of Subjects in 26 CFR Part 1**
Income taxes, Reporting and recordkeeping requirements.
**Correction of Publication**
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
**PART 1—INCOME TAXES**
**26 CFR Part 1**
*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**
*Par. 2.* Section 1.951A-2 is amended by adding a sentence at the end of paragraph (c)(7)(viii)(E)( *2* )( *ii* ) to read as follows:
§ 1.951A-2
(c) * * *
(7) * * *
(viii) * * *
(E) * * *
( *2* ) * * *
( *ii* ) * * * Notwithstanding the rule set forth in this paragraph (c)(7)(viii)(E)( *2* )( *ii* ), a controlled foreign corporation is not a member of a CFC group if, as of the close of its CFC inclusion year, the controlled foreign corporation does not have a controlling domestic shareholder.
Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).