Internal Revenue Bulletin: 2006-38
September 18, 2006
Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction
Table of Contents
This document contains corrections to temporary regulations (T.D. 9260, 2006-23 I.R.B. 1001) that were published in the Federal Register on Tuesday, April 25, 2006 (71 FR 24516) regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations under section 904(d)(4).
The temporary regulations (T.D. 9260) that are the subject of this correction are under section 904 of the Internal Revenue Code.
As published, (T.D. 9260) contains errors that may prove to be misleading and are in need of clarification.
Accordingly, the publication of the temporary regulations (T.D. 9260) which was the subject of FR Doc. 06-3882, is corrected as follows:
1. On page 24530, column 2, § 1.904-4, Instructional Par. 11., number 3, the language “3. In paragraph (e)(5)(iii), remove the language “and paragraph (9) of this section” and add the language “paid in taxable years beginning before January 1, 2003” in its place.” is corrected to read “3. In paragraph (e)(5)(iii), remove the language “and paragraph (g) of this section” and add the language “paid in taxable years beginning before January 1, 2003” in its place.”
Guy R. Traynor,
Chief, Publications and Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on August 18, 2006, 8:45 a.m., and published in the issue of the Federal Register for August 21, 2006, 71 F.R. 48474)
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