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.
Accordingly, the notice of proposed rulemaking (REG-135866-02) that was the subject of FR Doc. EG-8551 is corrected as follows:
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 USC 7805 * * *
Par. 2. On page 31991, instructional Par. 4. is amended by adding a new entry at the end of the amendatory instruction to read as follows:
6. Adding new paragraph (g).
Par. 3. On page 31991, section 1.1248-1 is amended by adding a new paragraph (g) to read as follows:
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(g) Effective date. Paragraph (a)(4) and paragraph (a)(5), Example 4, of this section apply to income inclusions that occur on or after the date that paragraph and example are published as final regulations in the Federal Register.
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Guy Traynor,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.