Document Headings

                    Document headings vary by document type but may contain                    the following:                  
                -                       the agency or agencies that issued and signed a document                    
                -                       the number of the CFR title and the number of each part                      the document amends, proposes to amend, or is directly                      related to                    
                -                       the agency docket number / agency internal file number                    
                -                       the RIN which identifies each regulatory action listed in                      the Unified Agenda of Federal Regulatory and Deregulatory                      Actions                    

                    See the                                          Document Drafting Handbook                                        for more details.                  

###### Department of the Treasury

###### Internal Revenue Service

          - 26 CFR Part 1
          - [TD 9222]
          - RIN 1545-BD49

# AGENCY:

Internal Revenue Service (IRS), Treasury.

# ACTION:

Correcting amendment.

# SUMMARY:

                        This document corrects final regulations (TD 9222) that were published in the                         **Federal Register**                         on Thursday, August 25, 2005 (70 FR 49864). The final regulations under section 951(a) of the Internal Revenue Code (Code) provide guidance for determining a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations.                    

# DATES:

This correction is effective August 25, 2005.

# FOR FURTHER INFORMATION CONTACT:

Jeffrey L. Vinnik, (202) 622-3840 (not a toll-free number).

# SUPPLEMENTARY INFORMATION:

## Background

The final regulations (TD 9222) that are the subject of this correction are under section 951(a) of the Internal Revenue Code.

## Need for Correction

As published, the final regulations (TD 9222) contain errors that may prove to be misleading and are in need of clarification.

# List of Subjects 26 CFR Part 1

      - Income taxes
      - Reporting and recordkeeping requirements

      ( print page 67906)    

## Correction of Publication

Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendment:

# PART 1—INCOME TAXES

**Paragraph 1.**                         The authority citation for part 1 continues to read in part as follows:                    

Authority:26 U.S.C. 7805 * * *

§ 1.951-1 

1. In § 1.951-1(a), the undesignated paragraph is designated as paragraph (a)(3). 

2. Section 1.951-1(e)(6), paragraph (ii) of *Example 5,*                         sixth sentence, the language “common shareholders by reference to the” is removed and the language “common shares by reference to the” is added in its place.                    

3. Section 1.951-1(e)(6), paragraph (i) of *Example 7,*                         sixth sentence, the language “income of United States shareholder under” is removed and the language “income of a United States shareholder under” is added in its place.                    

4. Section 1.951-1(e)(6), paragraph (i) of *Example 8,*                         third sentence, the language “Foreign Individual N, a foreign individual.” is removed and the language “Individual N, a foreign individual.” is added in its place.                    

Cynthia E. Grigsby,

Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).

[FR Doc. 05-22260 Filed 11-8-05; 8:45 am]

BILLING CODE 4830-01-P