This document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-102144-04, 2005-25 I.R.B. 1297) that was published in the Federal Register on Tuesday, May 24, 2005 (70 FR 29868). The proposed regulations provide guidance regarding dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group.
The notice of proposed rulemaking (REG-102144-04) that is the subject of these corrections are under sections 1503, 953 and 367 of the Internal Revenue Code.
As published, the notice of proposed rulemaking and notice of public hearing (REG-102144-04) contains errors that may prove to be misleading and are in need of clarification.
Accordingly, the notice of proposed rulemaking and notice of public hearing (REG-102144-04), that was the subject of FR Doc. 05-10160, is corrected as follows:
1. On page 29869, column 1, in the preamble under the paragraph heading “Background”, paragraph 3 from the top of the column, line 5, the language “as if such unit where a wholly owned” is corrected to read “as if such unit were a wholly owned”
2. On page 29897, column 2, “§1503(d)-4 (i)(1), line 6, the language, “through (ix) of this section, including” is corrected to read “through (viii) of this section, including”
3. On page 29903, column 2, §1.1503(d)-5(c), paragraph (i), of Example 34., the language, “its worldwide income Fx, a an unrelated” is corrected to read “its worldwide income, Fx, an unrelated”
Cynthia Grigsby,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.