Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income; Correcting Amendments

Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 9901] RIN 1545-BO55 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. SUMMARY: This document contains corrections to the Treasury Decision 9901, which was published in the Federal Register on Wednesday July 15, 2020. Treasury Decision 9901 contained final regulations that provide guidance regarding the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) and for coordinating the deduction for FDII and GILTI with other provisions in the Internal Revenue Code. DATES: These corrections are effective on October 28, 2020. For dates of applicability, see §§ 1.250-1(b) and 1.861-8(h). FOR FURTHER INFORMATION CONTACT: Brad McCormack at (202) 317-6911 and Lorraine Rodriguez at (202) 317-6726 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background The final regulations (TD 9901) that are the subject of this correction are under sections 250 and 861 of the Internal Revenue Code. Need for Correction As published on July 15, 2020 ( 85 FR 43042 ), the final regulations (TD 9901; FR Doc. 2020-14649 ) contains 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 continue…