# Prop. Treas. Reg. § 1.861-20: [Amended]

Proposed regulation, not in force. REG-105479-18, 89 FR 95362, published 2024-12-02 <https://www.federalregister.gov/documents/2024/12/02/2024-27227/previously-taxed-earnings-and-profits-and-related-basis-adjustments>. Interprets 26 U.S.C. § 861.

Par. 7. Section 1.861-20 is amended by: 1. In paragraph (a), adding the language “1.959-6,” after the language, “1.904-6,”; 2. In paragraph (d)(2)(ii)(B), adding the language “§ 1.959-6(c) and” before the language “§ 1.960-1(d)(3)(ii)”, and removing the language “income groups or PTEP groups” and adding the language “previously taxed earnings and profits and to income groups, respectively,” in its place; 3. In paragraph (d)(3)(i)(B)( 1 ), adding the language “§ 1.959-6(c) and” before the language “§ 1.960-1(d)(3)(ii)”, and removing the language “income groups or PTEP groups” and adding the language “previously taxed earnings and profits and to income groups, respectively,” in its place; and 4. In paragraph (g)(6)(i), removing the language “section 965(a) PTEP (as defined in § 1.960-3(c)(2)(vi)) in a single annual PTEP account (as defined in § 1.960-3(c)(1))” and adding the language “previously taxed earnings and profits assigned to the section 965(a) PTEP group (as defined in § 1.959-1(b)) within a single annual PTEP account (as defined in § 1.959-1(b))” in its place.