This document contains corrections to final regulations that were published in the Federal Register on July 20, 2004 (T.D. 9141, 2004-35 I.R.B. 359 [69 FR 43304]). This regulation relates to the section 904(d) foreign tax credit limitation and to the exclusion of certain export financing interest from foreign personal holding company income.
The final regulations that are the subject of these corrections are under section 904(d) of the Internal Revenue Code.
As published, T.D. 9141 contains errors that may prove to be misleading and are in need of clarification.
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Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 USC 7805 * * *
Par. 2. Section 1.904(b)-1(g) Example 3 (v), the introductory text is amended by removing the language “$424.87/$2571.42, computed as follows:” and adding the language “$412/$2571.42, computed as follows:” in its place.
Par. 3. Section 1.904(b)-1(g) Example 4 (iii), the second sentence is amended by removing the language “paragraph (c)(1) of this section. Under Step 1, the U.S. long-term capital loss adjustment amount is $50 ($80-$30). Under Step 2, the” and adding the language “paragraph (c)(1) of this section. Under Step 1, the U.S. long-term capital loss adjustment amount is $50 ($80-$30). Under Step 2, the” in its place.
Par. 4. Section 1.904-(b)-1(g) Example 5 (iii), the second sentence is amended by removing the language “Under Step 1, the U.S. long-term capital loss adjustment amount is $50 ($150-$100).” and adding the language “Under Step 1, the U.S. long-term capital loss adjustment amount is $50 ($150-$100).” in its place.
Par. 5. Section 1.904(b)-2, paragraph (c), the second sentence is amended by removing the language “apply §1.904(b)-1(i) and this” and adding the language “apply §1.904(b)-1 and this” in its place.
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.