Guidance Under Section 958 on Determining Stock Ownership; Correction
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Abstract
This document contains corrections to the final regulations (Treasury Decision 9960), published in the Federal Register on Tuesday, January 25, 2022. The final regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations.
Full Text
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<title>Federal Register, Volume 87 Issue 37 (Thursday, February 24, 2022)</title>
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[Federal Register Volume 87, Number 37 (Thursday, February 24, 2022)]
[Rules and Regulations]
[Pages 10305-10306]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-03612]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9960]
RIN 1545-BP79
Guidance Under Section 958 on Determining Stock Ownership;
Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final regulations; correction.
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SUMMARY: This document contains corrections to the final regulations
(Treasury Decision 9960), published in the Federal Register on Tuesday,
January 25, 2022. The final regulations regarding the treatment of
domestic partnerships for purposes of determining amounts included in
the gross income of their partners with respect to foreign
corporations.
DATES: These corrections are effective on February 24, 2022, and
applicable on or after January 25, 2022.
FOR FURTHER INFORMATION CONTACT: Edward J. Tracy at (202) 317-6934 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9960) subject to this correction are
issued under section 951 of the Internal Revenue Code.
Need for Correction
As published, the final regulations (TD 9960), contain errors that
need to be corrected.
Correction of Publication
Accordingly, the final regulation (TD 9960), that are the subject
of FR Doc. 2022-00066, published on January 25, 2022 (87 FR 3648), are
corrected to read as follows:
On page 3652, the third column, the thirty-second line through the
forty-third line from the top of the first full paragraph is corrected
to read ``year ending December 31, 2023. Accordingly, for their taxable
year ending December 31, 2023, the U.S. shareholder partners would have
a distributive share of the partnership's section 951 inclusion for the
CFC's taxable year ending December 31, 2022 (for the U.S. shareholder
partnership's taxable year ending June 30, 2023) and would also have a
direct section 951 inclusion for the CFC's
[[Page 10306]]
taxable year ending December 31, 2023.''
Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2022-03612 Filed 2-23-22; 8:45 am]
BILLING CODE 4830-01-P
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