This document corrects a notice of proposed rulemaking (REG-135866-02, 2006-27 I.R.B. 34) that was published in the Federal Register on Friday, June 2, 2006 (71 FR 31985) providing guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions.
The notice of proposed rulemaking (REG-135866-02) that is the subject of this correction is under section 1248 of the Internal Revenue Code.
As published, REG-135866-02 contains errors that may prove to be misleading and are in need of clarification.
Accordingly, the publication of the proposed regulations (REG-135866-02) which was the subject of FR. Doc. E6-8551, is corrected as follows:
| 1. | On page 31990, column 1, in the preamble, under the paragraph heading “Explanations of Provisions”, following the second full paragraph of the column, the following language is added: “F. Effective Date. |
These regulations are proposed to apply to income inclusions that occur on or after the date that final regulations are published in the Federal Register.”
| 2. | On page 31990, column 1, in the preamble, under the paragraph heading “Explanations of Provisions”, the language “F. Request for Comments” is corrected to read “G. Request for Comments”. |
The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.