81 FR 95541 - United States Property Held by Controlled Foreign Corporations Through Partnerships With Special Allocations; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 249 (December 28, 2016)

This document contains corrections to a notice of proposed rulemaking (REG-114734-16) that was published in the Federal Register on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations provide rules regarding the determination of the amount of the United States property treated as held by a controlled foreign corporation (CFC) through a partnership.

[Federal Register Volume 81, Number 249 (Wednesday, December 28, 2016)]
[Proposed Rules]
[Pages 95541-95542]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-31358]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-114734-16]
RIN 1545-BN51


United States Property Held by Controlled Foreign Corporations 
Through Partnerships With Special Allocations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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SUMMARY: This document contains corrections to a notice of proposed 
rulemaking (REG-114734-16) that was published in the Federal Register 
on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations 
provide rules regarding the

[[Page 95542]]

determination of the amount of the United States property treated as 
held by a controlled foreign corporation (CFC) through a partnership.

DATES: Written or electronic comments and request for a public hearing 
are still being accepted and must be received by February 1, 2017.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-114734-16), Room 
5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
114734-16), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW., Washington, DC, or sent electronically via the Federal 
eRulemaking Portal at http://www.regulations.gov (IRS REG-114734-16).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Rose E. Jenkins, (202) 317-6934; concerning submissions of comments or 
request for a public hearing, Regina Johnson, (202) 317-6901 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The notice of proposed rulemaking (REG-114734-16) that is the 
subject of this document is under sections 954 and 956 of the Internal 
Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-114734-16) 
contains errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking, (REG-114734-16), 
that was the subject of FR Doc. 2016-26424, is corrected as follows:

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1. On page 76543, first column, in the preamble, the sixth line from 
the top of the page, the language, ``property that does not have a 
principal'' is corrected to read ``property that is respected for 
Federal income tax purposes under section 704(b) and the regulations 
thereunder and does not have a principal''.


Sec.  1.956-4  [Corrected]

0
2. On page 76543, third column, third line from the bottom of paragraph 
(b)(2)(ii), the language ``allocation does not have a principal'' is 
corrected to read ``allocation will be respected for Federal income tax 
purposes under section 704(b) and the regulations thereunder and does 
not have a principal''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-31358 Filed 12-27-16; 8:45 am]
BILLING CODE 4830-01-P