Treasury Department, Internal Revenue Service
This document contains corrections to the final regulations (Treasury Decision 9922) that were published in the Federal Register on Thursday, November 12, 2020. Treasury Decision 9922 provided guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments, and the treatment of certain payments under the global intangible low-taxed income provisions.
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 9922] RIN 1545-BP21; 1545-BP22 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. SUMMARY: This document contains corrections to the final regulations (Treasury Decision 9922) that were published in the Federal Register on Thursday, November 12, 2020. Treasury Decision 9922 provided guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments, and the treatment of certain payments under the global intangible low-taxed income provisions. DATES: Effective on October 1, 2021, and applicable as of November 12, 2020. FOR FURTHER INFORMATION CONTACT: Concerning §§ 1.861-8 and 1.861-17, Jeffrey P. Cowan, (202) 317-4924; concerning §§ 1.861-20, 1.904-4, and 1.904-6, Suzanne M. Walsh, (202) 317-4908; concerning § 1.881-3, Richard F. Owens, (202) 317-6501; concerning § 1.904(g)-3, Jeffrey L. Parry, (202) 317 4916; concerning § 1.905-4T, Corina Braun, (202) 317-5004 (not toll-free numbers). Bac…
Other Federal Register documents from the same docket.
Citation: 86 FR 54367
