80 FR 22954 - Exception From Passive Income for Certain Foreign Insurance Companies

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 80, Issue 79 (April 24, 2015)

Page Range		22954-22956
FR Document		2015-09630

This document contains proposed regulations that provide guidance regarding when a foreign insurance company's income is excluded from the definition of passive income under section 1297(b)(2)(B). The proposed regulations affect the U.S. shareholders of foreign corporations. This document also invites comments from the public on all aspects of the proposed rules and provides the opportunity for the public to request a public hearing.

Federal Register, Volume 80 Issue 79 (Friday, April 24, 2015)

[Federal Register Volume 80, Number 79 (Friday, April 24, 2015)]
[Proposed Rules]
[Pages 22954-22956]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-09630]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-108214-15]
RIN 1545-BM69


Exception From Passive Income for Certain Foreign Insurance 
Companies

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking.

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SUMMARY: This document contains proposed regulations that provide 
guidance regarding when a foreign insurance company's income is 
excluded from the definition of passive income under section 
1297(b)(2)(B). The proposed regulations affect the U.S. shareholders of 
foreign corporations. This document also invites comments from the 
public on all aspects of the proposed rules and provides the 
opportunity for the public to request a public hearing.

DATES: Written or electronic comments and requests for a public hearing 
must be received by July 23, 2015.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-108214-15), 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-
108214-15), 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-108214-15).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Josephine Firehock, (202) 317-4932; concerning submissions of comments 
or requests for a public hearing, Oluwafunmilayo (Funmi) Taylor at 
(202) 317-6901 (not toll-free numbers).

SUPPLEMENTARY INFORMATION: 

Background and Explanation of Provisions

    The Department of Treasury (Treasury) and the IRS are aware of 
situations in which a hedge fund establishes a purported foreign 
reinsurance company in order to defer and reduce the tax that otherwise 
would be due with respect to investment income. Such foreign 
corporations may be Passive Foreign Investment Companies (PFICs). For a 
description of the recent trends and legislative proposals to address 
the issue, see ``Background and Data with Respect to Hedge Fund 
Reinsurance Arrangements,'' JCT (July 31, 2014) (2014 JCT Report); see 
also Notice 2003-34, 2003-23 IRB 990 (May 9, 2003).
    Under section 1297 of the Internal Revenue Code (Code), a foreign 
corporation is a PFIC if either 75 percent or more of its gross income 
for the taxable year is passive income (``passive income test''), or on 
average 50 percent or more of its assets produce passive income or are 
held for the production of passive income (``passive asset test''). 
Section 1297(b)(1) generally defines the term ``passive income'' to 
mean any income of a kind that would be ``foreign personal holding 
company income'' as defined in section 954(c). In general, an asset is 
characterized as passive if it generates (or is reasonably expected to 
generate in the reasonably foreseeable future) passive income as 
defined in section 1297(b). Assets that generate both passive and non-
passive income in a taxable year are treated as partly passive and 
partly non-passive assets in proportion to the relative amounts of 
income generated by those assets in that year. See Notice 88-22, 1988-1 
CB 489 (February 26, 1988).
    For purposes of applying the passive income test, section 
1297(b)(2)(B) provides that, except as provided in regulations, the 
term ``passive income'' does not include any income that is derived in 
the active conduct of an insurance business by a corporation which is 
predominantly engaged in an insurance business and which would be 
subject to tax under subchapter L as an insurance company if the 
corporation were a domestic corporation. As the terms ``active 
conduct'' and ``insurance business'' are not defined in section 1297, 
Treasury and the IRS are proposing regulations to clarify the 
circumstances under which investment income earned by a foreign 
insurance company is derived in the active conduct of an insurance 
business for purposes of determining whether the income is passive 
income, and thus the extent to which the company's assets are treated 
as passive assets for purposes of determining whether the company is a 
PFIC.
    The proposed regulations provide that the term ``active conduct'' 
has the same meaning as in Sec.  1.367(a)-2T(b)(3), except that 
officers and employees are not considered to include the officers and 
employees of related entities. The proposed regulations define the term 
``insurance business'' to mean the business activity of issuing 
insurance and annuity contracts and the reinsuring of risks 
underwritten by insurance companies, together with investment 
activities and administrative services that are required to support or 
are substantially related to insurance contracts issued or reinsured by 
the foreign insurance company.\1\ The regulations also provide that an

[[Page 22955]]

investment activity is any activity engaged in to produce income of a 
kind that would be foreign personal holding company income as defined 
in section 954(c). The proposed regulations further provide that 
investment activities will be treated as required to support or as 
substantially related to insurance or annuity contracts issued or 
reinsured by the foreign corporation to the extent that income from the 
activities is earned from assets held by the foreign corporation to 
meet obligations under the contracts.
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    \1\ Cf. Committee on Ways and Means U.S. House of 
Representatives, Supplemental Report, The Deficit Reduction Act of 
1984, 98th Cong. 2d Sess., H.R. Rept. 98-432, part 2, at 531 (Mar. 
5, 1984); Committee on Finance United States Senate, The Deficit 
Reduction Act of 1984, S. Rept. 98-169, vol. 1, at 1407-08 (April 2, 
1984); H.R. Rept. 98-861, 98th Cong. 2d Sess. at 1045 (June 23, 
1984) (Conference Report).
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    The proposed regulations do not set forth a method to determine the 
portion of assets held to meet obligations under insurance and annuity 
contracts. Comments are requested on appropriate methodologies for 
determining the extent to which assets are held to meet obligations 
under insurance and annuity contracts.
    The proposed regulations also do not define what it means to be 
``predominantly engaged'' in an insurance business. Prior to 1984, the 
Code did not define an insurance company. Section 1.801-3(a) of the 
regulations, however, provides in relevant part that an insurance 
company is a company whose primary and predominant business activity 
during the taxable year is the issuing of insurance or annuity 
contracts or the reinsuring of risks underwritten by insurance 
companies.
    In 1984, Congress enacted a definition of an ``insurance company'' 
that applied only to life insurance companies, and in 2004, a 
conforming amendment was made to apply the same definition to non-life 
insurance companies. See sections 816(a) and 831(c). Under this 
definition, in order for a corporation to be subject to tax as an 
insurance company under subchapter L, more than half of its business 
during the taxable year is required to be the issuing of insurance or 
annuity contracts or the reinsuring of risks underwritten by insurance 
companies. By requiring that more than half of the company's business 
activity, rather than its predominant business activity, be insurance 
activity, the current subchapter L statutory rules adopt a stricter and 
more precise standard than the ``primary and predominant'' regulatory 
standard under prior law.\2\ Thus, any company taxable under subchapter 
L as an insurance company is necessarily predominantly engaged in an 
insurance business for purposes of section 1297(a)(2)(B).
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    \2\ Committee on Ways and Means U.S. House of Representatives, 
Supplemental Report, The Deficit Reduction Act of 1984, 98th Cong. 
2d Sess., H.R. Rept. 98-432, part 2, at 1402-3 (March 5, 1984); 
Committee on Finance United States Senate, The Deficit Reduction Act 
of 1984, 98th Cong. 2d Sess., S. Rpt. 98-169, vol. 1, at 525-6 
(April 2, 1984); Committee on Ways and Means U.S. House of 
Representatives, Supplemental Report, The Deficit Reduction Act of 
1984, 98th Cong. 2d Sess., H.R. Rept. 98-432, part 2, at 1042-2 
(March 5, 1984) (Conference Report); H.R. Rept. 108-457, Pension 
Funding Equity Act of 2004, 108th Cong. 2d Sess. at 52-53 (April 1, 
2004).
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Proposed Effective/Applicability Date

    These regulations are proposed to apply on the date of publication 
of the Treasury decision adopting these rules as final regulations in 
the Federal Register.

Special Analyses

    It has been determined that this notice of proposed rulemaking is 
not a significant regulatory action as defined in Executive Order 
12866, as supplemented by Executive Order 13563. Therefore, a 
regulatory assessment is not required. It also has been determined that 
section 553(b) of the Administrative Procedure Act (5 U.S.C. Chapter 5) 
does not apply to these regulations, and because the regulations do not 
impose a collection of information on small entities, the Regulatory 
Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to 
section 7805(f) of the Code, this notice of proposed rulemaking has 
been submitted to the Chief Counsel of Advocacy of the Small Business 
Administration for comment on its impact on small business.

Comments and Requests for Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any comments that are submitted timely 
to the IRS as prescribed in this preamble under ``Addresses.'' Treasury 
and the IRS request comments on all aspects of the proposed rules. 
Comments specifically are requested with regard to how to determine the 
portion of a foreign insurance company's assets that are held to meet 
obligations under insurance contracts issued or reinsured by the 
company. For example, assets could be considered as held to meet 
obligations under insurance or annuity contracts issued or reinsured by 
the corporation to the extent the corporation's assets in the calendar 
year do not exceed a specified percentage of the corporation's total 
insurance liabilities for the year (for example, the sum of the 
corporation's ``total reserves'' (as defined in section 816(c)) plus 
(to the extent not included in total reserves) the items referred to in 
paragraphs (3), (4), (5), and (6) of section 807(c)). Comments are 
requested with regard to what percentage would be appropriate. Also, 
comments are requested with regard to whether other methods would be 
more appropriate to determine the portion of assets that are held to 
meet obligations under insurance and annuity contracts.
    All comments will be available at www.regulations.gov or upon 
request. A public hearing will be scheduled if requested in writing by 
any person that timely submits comments. If a public hearing is 
scheduled, notice of the date, time, and place for the public hearing 
will be published in the Federal Register.

Drafting Information

    The principal author of these proposed regulations is Josephine 
Firehock of the Office of Associate Chief Counsel (International). 
However, other personnel from the IRS and the Treasury Department 
participated in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

    Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

0
Par. 1. The authority citation for part 1 is amended by adding an entry 
in numerical order to read in part as follows:

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

    Section 1.1297-4 is also issued under 26 U.S.C. 1297(b)(2)(B) 
and 1298(g).

0
Par. 2. Section 1.1297-4 is added to read as follows:


Sec.  1.1297-4  Exception from the definition of passive income for 
certain foreign insurance company income.

    (a) Income derived in the active conduct of an insurance business. 
For purposes of section 1297, the term passive income does not include 
income earned by a foreign corporation that would be subject to tax 
under subchapter L if it were a domestic corporation, but only to the 
extent the income is derived in the active conduct of an insurance 
business.
    (b) Definitions. The following definitions apply for purposes of 
paragraph (a) of this section--
    (1) Active conduct. The term active conduct has the same meaning as 
in Sec.  1.367(a)-2T(b)(3), except that officers and employees are not 
considered to

[[Page 22956]]

include the officers and employees of related entities as provided in 
Sec.  1.367(a)-2T(b)(3).
    (2) Insurance business. The term insurance business means the 
business of issuing insurance and annuity contracts and the reinsuring 
of risks underwritten by insurance companies, together with those 
investment activities and administrative services that are required to 
support or are substantially related to insurance and annuity contracts 
issued or reinsured by the foreign corporation. For purposes of the 
preceding sentence--
    (i) An investment activity is any activity engaged in by the 
foreign corporation to produce income of a kind that would be foreign 
personal holding company income as defined in section 954(c); and
    (ii) Investment activities are required to support or are 
substantially related to insurance and annuity contracts issued or 
reinsured by the foreign corporation to the extent that income from the 
activities is earned from assets held by the foreign corporation to 
meet obligations under the contracts.
    (c) Effective/applicability date. These regulations apply beginning 
[EFFECTIVE DATE OF FINAL RULE].

John M. Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2015-09630 Filed 4-23-15; 8:45 am]
 BILLING CODE 4830-01-P

22954 Federal Register / Vol. 80, No. 79 / Friday, April 24, 2015 / Proposed Rules

request comments on its proposal to SUMMARY: This document contains term ‘‘passive income’’ to mean any
implement portions of Title XI of the proposed regulations that provide income of a kind that would be ‘‘foreign
MMA, which amended provisions of the guidance regarding when a foreign personal holding company income’’ as
FD&C Act that govern the approval of insurance company’s income is defined in section 954(c). In general, an
505(b)(2) applications and ANDAs. FDA excluded from the definition of passive asset is characterized as passive if it
also requested comment on its proposal income under section 1297(b)(2)(B). The generates (or is reasonably expected to
to amend certain regulations regarding proposed regulations affect the U.S. generate in the reasonably foreseeable
505(b)(2) applications and ANDAs to shareholders of foreign corporations. future) passive income as defined in
facilitate compliance with and efficient This document also invites comments section 1297(b). Assets that generate
enforcement of the FD&C Act. from the public on all aspects of the both passive and non-passive income in
Comments on the proposed rule will proposed rules and provides the a taxable year are treated as partly
inform FDA’s rulemaking on ANDAs opportunity for the public to request a passive and partly non-passive assets in
and 505(b)(2) applications. public hearing. proportion to the relative amounts of
The Agency has received requests for DATES: Written or electronic comments income generated by those assets in that
a 60-day extension of the comment and requests for a public hearing must year. See Notice 88–22, 1988–1 CB 489
period for the proposed rule. Each be received by July 23, 2015. (February 26, 1988).
request conveyed concern that the ADDRESSES: Send submissions to: For purposes of applying the passive
current 90-day comment period does CC:PA:LPD:PR (REG–108214–15), Room income test, section 1297(b)(2)(B)
not allow sufficient time to develop a 5203, Internal Revenue Service, P.O. provides that, except as provided in
meaningful or thoughtful response to Box 7604, Ben Franklin Station, regulations, the term ‘‘passive income’’
the proposed rule. Washington, DC 20044. Submissions does not include any income that is
FDA has considered the requests and may be hand-delivered Monday through derived in the active conduct of an
is extending the comment period for the Friday between the hours of 8 a.m. and insurance business by a corporation
proposed rule for 30 days, until June 8, 4 p.m. to CC:PA:LPD:PR (REG–108214– which is predominantly engaged in an
2015. The Agency believes that a 30-day 15), Courier’s Desk, Internal Revenue insurance business and which would be
extension of the comment period for the Service, 1111 Constitution Avenue NW., subject to tax under subchapter L as an
proposed rule allows adequate time for Washington, DC, or sent electronically insurance company if the corporation
interested persons to submit comments via the Federal eRulemaking Portal at were a domestic corporation. As the
without significantly delaying http://www.regulations.gov (IRS REG– terms ‘‘active conduct’’ and ‘‘insurance
rulemaking on these important issues. 108214–15). business’’ are not defined in section
1297, Treasury and the IRS are
II. Request for Comments FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations, proposing regulations to clarify the
Interested persons may submit either circumstances under which investment
electronic comments regarding this Josephine Firehock, (202) 317–4932;
concerning submissions of comments or income earned by a foreign insurance
document to http://www.regulations.gov company is derived in the active
or written comments to the Division of requests for a public hearing,
Oluwafunmilayo (Funmi) Taylor at conduct of an insurance business for
Dockets Management (see ADDRESSES). It purposes of determining whether the
is only necessary to send one set of (202) 317–6901 (not toll-free numbers).
income is passive income, and thus the
comments. Identify comments with the SUPPLEMENTARY INFORMATION:
extent to which the company’s assets
docket number found in brackets in the Background and Explanation of are treated as passive assets for purposes
heading of this document. Received Provisions of determining whether the company is
comments may be seen in the Division a PFIC.
of Dockets Management between 9 a.m. The Department of Treasury
(Treasury) and the IRS are aware of The proposed regulations provide that
and 4 p.m., Monday through Friday, and the term ‘‘active conduct’’ has the same
will be posted to the docket at http:// situations in which a hedge fund
establishes a purported foreign meaning as in § 1.367(a)–2T(b)(3),
www.regulations.gov. except that officers and employees are
reinsurance company in order to defer
Dated: April 17, 2015. and reduce the tax that otherwise would not considered to include the officers
Leslie Kux, be due with respect to investment and employees of related entities. The
Associate Commissioner for Policy. income. Such foreign corporations may proposed regulations define the term
be Passive Foreign Investment ‘‘insurance business’’ to mean the
[FR Doc. 2015–09523 Filed 4–23–15; 8:45 am]
Companies (PFICs). For a description of business activity of issuing insurance
BILLING CODE 4164–01–P
the recent trends and legislative and annuity contracts and the
proposals to address the issue, see reinsuring of risks underwritten by
‘‘Background and Data with Respect to insurance companies, together with
DEPARTMENT OF THE TREASURY investment activities and administrative
Hedge Fund Reinsurance
Arrangements,’’ JCT (July 31, 2014) services that are required to support or
Internal Revenue Service
(2014 JCT Report); see also Notice 2003– are substantially related to insurance
34, 2003–23 IRB 990 (May 9, 2003). contracts issued or reinsured by the
26 CFR Part 1
Under section 1297 of the Internal foreign insurance company.1 The
[REG–108214–15] regulations also provide that an
Revenue Code (Code), a foreign
tkelley on DSK3SPTVN1PROD with PROPOSALS

RIN 1545–BM69 corporation is a PFIC if either 75 percent 1 Cf. Committee on Ways and Means U.S. House
or more of its gross income for the of Representatives, Supplemental Report, The
Exception From Passive Income for taxable year is passive income (‘‘passive Deficit Reduction Act of 1984, 98th Cong. 2d Sess.,
Certain Foreign Insurance Companies income test’’), or on average 50 percent H.R. Rept. 98–432, part 2, at 531 (Mar. 5, 1984);
or more of its assets produce passive Committee on Finance United States Senate, The
AGENCY: Internal Revenue Service (IRS), Deficit Reduction Act of 1984, S. Rept. 98–169, vol.
Treasury. income or are held for the production of 1, at 1407–08 (April 2, 1984); H.R. Rept. 98–861,
passive income (‘‘passive asset test’’). 98th Cong. 2d Sess. at 1045 (June 23, 1984)
ACTION: Notice of proposed rulemaking.
Section 1297(b)(1) generally defines the (Conference Report).

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22956 Federal Register / Vol. 80, No. 79 / Friday, April 24, 2015 / Proposed Rules

include the officers and employees of Department of Environmental Services provide it in the body of your comment.
related entities as provided in (NH DES) committed to revising its If you send an email comment directly
§ 1.367(a)–2T(b)(3). regulations no later than one year from to EPA without going through
(2) Insurance business. The term the date when EPA publishes a notice www.regulations.gov your email address
insurance business means the business of final conditional approval, and to will be automatically captured and
of issuing insurance and annuity submitting the revised regulations to included as part of the comment that is
contracts and the reinsuring of risks EPA for approval into the SIP. EPA is placed in the public docket and made
underwritten by insurance companies, also proposing to fully approve a July 1, available on the Internet. If you submit
together with those investment activities 2003 SIP revision that clarifies two an electronic comment, EPA
and administrative services that are definitions related to New Hampshire’s recommends that you include your
required to support or are substantially permitting programs. These actions are name and other contact information in
related to insurance and annuity being taken in accordance with the the body of your comment and with any
contracts issued or reinsured by the Clean Air Act (CAA). disk or CD–ROM you submit. If EPA
foreign corporation. For purposes of the DATES: Written comments must be cannot read your comment due to
preceding sentence— received on or before May 26, 2015. technical difficulties and cannot contact
(i) An investment activity is any ADDRESSES: Submit your comments, you for clarification, EPA may not be
activity engaged in by the foreign identified by Docket ID Number EPA– able to consider your comment.
corporation to produce income of a kind R01–OAR–2014–0796 by one of the Electronic files should avoid the use of
that would be foreign personal holding following methods: special characters, any form of
company income as defined in section 1. www.regulations.gov: Follow the encryption, and be free of any defects or
954(c); and on-line instructions for submitting viruses.
(ii) Investment activities are required comments. Docket: All documents in the
to support or are substantially related to 2. Email: mcdonnell.ida@epa.gov electronic docket are listed in the
insurance and annuity contracts issued 3. Fax: (617) 918–0653 www.regulations.gov index. Although
or reinsured by the foreign corporation 4. Mail: ‘‘Docket Identification listed in the index, some information is
to the extent that income from the Number EPA–R01–OAR–2014–0796’’, not publicly available, i.e., CBI or other
activities is earned from assets held by Ida McDonnell, U.S. Environmental information whose disclosure is
the foreign corporation to meet Protection Agency, EPA New England restricted by statute. Certain other
obligations under the contracts. Regional Office, Office of Ecosystem material, such as copyrighted material,
(c) Effective/applicability date. These Protection, Air Permits, Toxics, and is not placed on the Internet and will be
regulations apply beginning Indoor Programs Unit, 5 Post Office publicly available only in hard copy
[EFFECTIVE DATE OF FINAL RULE]. Square—Suite 100, (Mail code OEP05– form. Publicly available docket
2), Boston, MA 02109–3912. materials are available either
John M. Dalrymple,
5. Hand Delivery or Courier. Deliver electronically in www.regulations.gov or
Deputy Commissioner for Services and
your comments to: Ida McDonnell, in hard copy at Office of Ecosystem
Enforcement.
Manager, Air Permits, Toxics, and Protection, U.S. Environmental
[FR Doc. 2015–09630 Filed 4–23–15; 8:45 am]
Indoor Programs Unit, U.S. Protection Agency, EPA New England
BILLING CODE 4830–01–P
Environmental Protection Agency, EPA Regional Office, Air Permits, Toxics and
New England Regional Office, Office of Indoor Programs Unit, 5 Post Office
Ecosystem Protection, 5 Post Office Square—Suite 100, Boston, MA. EPA
ENVIRONMENTAL PROTECTION requests that if at all possible, you
Square—Suite 100, (mail code OEP05–
AGENCY contact the contact listed in the FOR
2), Boston, MA 02109–3912. Such
deliveries are only accepted during the FURTHER INFORMATION CONTACT section to
40 CFR Part 52
Regional Office’s normal hours of schedule your inspection. The Regional
[EPA–R01–OAR–2014–0796; EPA–R01– operation. The Regional Office’s official Office’s official hours of business are
OAR–2014–0862; FRL–9926–73–Region 1] hours of business are Monday through Monday through Friday, 8:30 a.m. to
Friday, 8:30 a.m. to 4:30 p.m., excluding 4:30 p.m., excluding legal holidays.
Approval and Promulgation of Air In addition, copies of the state
legal holidays.
Quality Implementation Plans; New submittal and EPA’s proposed approval
Instructions: Direct your comments to
Hampshire; Nonattainment New and technical support document are
Docket ID No. EPA–R01–OAR–2014–
Source Review and Prevention of also available for public inspection
0796. EPA’s policy is that all comments
Significant Deterioration Program during normal business hours, by
received will be included in the public
AGENCY: Environmental Protection docket without change and may be appointment at the Air Resources
Agency (EPA). made available online at Division, New Hampshire Department
www.regulations.gov, including any of Environmental Services, 6 Hazen
ACTION: Proposed rule.
personal information provided, unless Drive, P.O. Box 95, Concord, NH 03302–
SUMMARY: The Environmental Protection the comment includes information 0095.
Agency (EPA) is proposing to claimed to be Confidential Business FOR FURTHER INFORMATION CONTACT:
conditionally approve the New Information (CBI) or other information Brendan McCahill, U.S. Environmental
Hampshire November 15, 2012 State whose disclosure is restricted by statute. Protection Agency, EPA New England
tkelley on DSK3SPTVN1PROD with PROPOSALS

Implementation Plan (SIP) revisions that Do not submit through Regional Office, Office of Ecosystem
are intended to ensure that the State’s www.regulations.gov, or email, Protection, Air Permits, Toxics, and
Prevention of Significant Deterioration information that you consider to be CBI Indoor Programs Unit, 5 Post Office
(PSD) and Nonattainment New Source or otherwise protected. The Square—Suite 100, (mail code OEP05–
Review (NNSR) programs are consistent www.regulations.gov Web site is an 2), Boston, MA 02109–3912, telephone
with the federal PSD and NNSR ‘‘anonymous access’’ system, which number (617) 918–1652, Fax number
program requirements. In a letter dated means EPA will not know your identity (617) 918–0652, email
March 20, 2015, the New Hampshire or contact information unless you mccahill.brendan@EPA.GOV.

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Document Created: 2015-12-16 08:43:06
Document Modified: 2015-12-16 08:43:06

Category		Regulatory Information
Collection		Federal Register
sudoc Class		AE 2.7: GS 4.107: AE 2.106:
Publisher		Office of the Federal Register, National Archives and Records Administration
Section		Proposed Rules
Action		Notice of proposed rulemaking.
Dates		Written or electronic comments and requests for a public hearing must be received by July 23, 2015.
Contact		Concerning the proposed regulations, Josephine Firehock, (202) 317-4932; concerning submissions of comments or requests for a public hearing, Oluwafunmilayo (Funmi) Taylor at (202) 317-6901 (not toll-free numbers).
FR Citation		80 FR 22954
RIN Number		1545-BM69
CFR Associated		Income Taxes and Reporting and Recordkeeping Requirements

80 FR 22954 - Exception From Passive Income for Certain Foreign Insurance Companies

DEPARTMENT OF THE TREASURYInternal Revenue Service

Federal Register Volume 80, Issue 79 (April 24, 2015)

DEPARTMENT OF THE TREASURY
Internal Revenue Service