IRS Corrects Final Regs on Stock Ownership Rules

Guidance Under Section 958 on Determining Stock Ownership; Correction

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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1

Treasury Decision 9960

RIN 1545-BP79

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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 22, 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 on January 25, 2022 (87 FR 3648), the final regulations (TD 9960) 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

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

§1.958-1 [Corrected]

Par. 2. Section 1.958-1(d)(3)(iii)(B)(3) is corrected by removing the word "note" and adding the word "account" in its place.

Oluwafunmilayo A. Taylor,
Chief,
Publications and Regulations Branch,
Legal Processing Division,
Associate Chief Counsel,
(Procedure and Administration).

[FR Doc. 2022-03611 Filed: 2/18/2022 8:45 am; Publication Date: 2/22/2022]