80_FR_66625 80 FR 66416 - United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction

80 FR 66416 - United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 80, Issue 209 (October 29, 2015)

Page Range66416-66417
FR Document2015-27604

This document contains corrections to final and temporary regulations (TD 9733) that were published in the Federal Register on September 2, 2015 (80 FR 52976). The temporary regulations are regarding the treatment as United States property of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.

Federal Register, Volume 80 Issue 209 (Thursday, October 29, 2015) 
[Federal Register Volume 80, Number 209 (Thursday, October 29, 2015)]
[Rules and Regulations]
[Pages 66416-66417]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-27604]


-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9733]
RIN 1545-BJ49


United States Property Held by Controlled Foreign Corporations in 
Transactions Involving Partnerships; Rents and Royalties Derived in the 
Active Conduct of a Trade or Business; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correction.

-----------------------------------------------------------------------

SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9733) that were published in the Federal Register on 
September 2, 2015 (80 FR 52976). The temporary regulations are 
regarding the treatment as United States property of property held by a 
controlled foreign corporation in connection with certain transactions 
involving partnerships.

DATES: This correction is effective on October 29, 2015 and applicable 
beginning September 2, 2015.

FOR FURTHER INFORMATION CONTACT: Rose E. Jenkins at (202) 317-6934 (not 
a toll free number).

SUPPLEMENTARY INFORMATION:

[[Page 66417]]

Background

    The final and temporary regulations (TD 9733) that are the subject 
of this correction are under sections 954 and 956 of the Internal 
Revenue Code.

Need for Correction

    As published, the final and temporary regulations (TD 9733) contain 
errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the final and temporary regulations (TD 9733), that 
are the subject of FR Doc. 2015-21574, are corrected as follows:
    1. On page 52977, in the preamble, the first column, under the 
paragraph heading ``Background'', the second line of the paragraph, the 
language ``to 26 CFR part 1 under of the Internal'' is corrected to 
read ``to 26 CFR part 1 under section 956 of the Internal''.
    2. On page 52979, in the preamble, the second column, the first 
line of the column, the language ``the active development test in 
Sec. Sec.  1.954-'' is corrected to read ``the active development test 
in Sec.  1.954-''.
    3. On page 52979, in the preamble, the second column, the twentieth 
line of the column, the language ``Sec. Sec.  1.954-2T(c)(2)(iii)(E), 
(c)(2)(viii),'' is corrected to read ``Sec.  1.954-2T(c)(2)(iii)(E), 
(c)(2)(viii),''.
    4. On page 52979, in the preamble, the second column, the twelfth 
line from the bottom of the column, the language ``that such rents or 
royalties that are'' is corrected to read that such rents or royalties 
are''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-27604 Filed 10-28-15; 8:45 am]
BILLING CODE 4830-01-P

66416 Federal Register / Vol. 80, No. 209 / Thursday, October 29, 2015 / Rules and Regulations property held by a controlled foreign guidance, see § 1.954–2(d)(2)(iii) (g) * * * (1) Paragraph (b)(4) of this corporation in connection with certain introductory text through (d)(2)(iii)(D). section applies to taxable years of transactions involving partnerships. * * * * * controlled foreign corporations ending DATES: This correction is effective on (j) * * * See § 1.954–2(c)(1)(i), on or after September 1, 2015, and to October 29, 2015 and applicable (c)(1)(iv), (c)(2)(ii), (c)(2)(iii), (d)(1)(i), taxable years of United States beginning September 2, 2015. (d)(1)(ii), (d)(2)(ii), and (d)(2)(iii), as shareholders in which or with which FOR FURTHER INFORMATION CONTACT: Rose contained in 26 CFR part 1 revised as of such taxable years end, with respect to E. Jenkins at (202) 317–6934 (not a toll April 1, 2015, for rules applicable to property acquired on or after September free number). rents or royalties, as applicable, 1, 2015. See paragraph (b)(4) of § 1.956– received or accrued before September 1, 1T, as contained in 26 CFR part 1 SUPPLEMENTARY INFORMATION: revised as of April 1, 2015, for the rules 2015. Background * * * * * applicable to taxable years of controlled foreign corporations ending before The final and temporary regulations ■ Par. 3. Section 1.956–1 is amended by September 1, 2015, and property (TD 9733) that are the subject of this revising paragraph (g) introductory text acquired before September 1, 2015. For correction are under sections 954 and through (g)(3) to read as follows: purposes of this paragraph (g)(1), a 956 of the Internal Revenue Code. deemed exchange of property pursuant § 1.956–1 Shareholder’s pro rata share of Need for Correction a controlled foreign corporation’s increase to section 1001 on or after September 1, in earnings invested in United States 2015, constitutes an acquisition of the As published, the final and temporary property. property on or after that date. regulations (TD 9733) contain errors that may prove to be misleading and are in * * * * * * * * * * need of clarification. (g) introductory text through (g)(3) Martin V. Franks, [Reserved]. For further guidance, see List of Subjects in 26 CFR Part 1 Chief, Publications and Regulations Branch, § 1.956–1T(g) introductory text through Legal Processing Division, Associate Chief Income taxes, Reporting and (g)(3). Counsel (Procedure and Administration). recordkeeping requirements. * * * * * [FR Doc. 2015–27603 Filed 10–28–15; 8:45 am] Correction of Publication ■ Par. 4. Section 1.956–1T is amended BILLING CODE 4830–01–P by revising paragraph (b)(4)(ii), the third Accordingly, 26 CFR part 1 is sentence of paragraph (b)(4)(iv) Example corrected by making the following 1. (i), the first sentence of paragraph DEPARTMENT OF THE TREASURY correcting amendments: (b)(4)(iv) Example 3. (i), and paragraph (g)(1) to read as follows: Internal Revenue Service PART 1—INCOME TAXES § 1.956–1T Shareholder’s pro rata share of 26 CFR Part 1 ■ Paragraph 1. The authority citation a controlled foreign corporation’s increase for part 1 continues to read in part as in earnings invested in United States [TD 9733] follows: property (temporary). Authority: 26 U.S.C. 7805 * * * * * * * * RIN 1545–BJ49 (b) * * * ■ Par. 2. Section 1.954–2T is amended (4) * * * United States Property Held by by revising paragraph (a)(1) through (ii) Control. For purposes of Controlled Foreign Corporations in (c)(1) introductory text, paragraph paragraphs (b)(4)(i)(B) and (C) of this Transactions Involving Partnerships; (c)(2)(iii) introductory text through section, a controlled foreign corporation Rents and Royalties Derived in the (c)(2)(iii)(D), paragraph (c)(3) and (d)(1) controls a foreign corporation or Active Conduct of a Trade or introductory text, (d)(2)(iii) introductory partnership if the controlled foreign Business; Correction text through (d)(2)(iii)(D), and the last corporation and the other foreign sentence of paragraph (j) to read as AGENCY: Internal Revenue Service (IRS), corporation or partnership are related Treasury. follows: within the meaning of section 267(b) or ACTION: Final and temporary § 1.954–3T Foreign personal holding section 707(b). For this purpose, in determining whether two corporations regulations; correction. company income (temporary). (a)(1) through (c)(1) introductory text are members of the same controlled SUMMARY: This document contains [Reserved]. For further guidance, see group under section 267(b)(3), a person corrections to final and temporary § 1.954–2(a)(1) through (c)(1) is considered to own stock owned regulations (TD 9733) that were introductory text. directly by such person, stock owned for published in the Federal Register on the purposes of section 1563(e)(1), and September 2, 2015 (80 FR 52976). The * * * * * stock owned with the application of temporary regulations are regarding the (c)(2)(iii) introductory text through section 267(c). treatment as United States property of (c)(2)(iii)(D) [Reserved]. For further guidance, see § 1.954–2(c)(2)(iii) * * * * * property held by a controlled foreign introductory text through (c)(2)(iii)(D). (iv) * * * corporation in connection with certain Example 1. (i) * * * FS2 has no earnings transactions involving partnerships. * * * * * and profits, and FS1 has substantial (c)(3) and (d)(1) introductory text DATES: This correction is effective on rmajette on DSK7SPTVN1PROD with RULES accumulated earnings and profits. * * * [Reserved]. For further guidance, see October 29, 2015 and applicable * * * * * beginning September 2, 2015. § 1.954–2(c)(3) and (d)(1) introductory Example 3. (i) * * * FS1 has $100x of text. post-1986 undisturbed earnings and profits FOR FURTHER INFORMATION CONTACT: Rose * * * * * and $100x post-1986 foreign income taxes, E. Jenkins at (202) 317–6934 (not a toll (d)(2)(iii) introductory text through but does not have any cash. * * * free number). (d)(2)(iii)(D) [Reserved]. For further * * * * * SUPPLEMENTARY INFORMATION: VerDate Sep<11>2014 13:13 Oct 28, 2015 Jkt 238001 PO 00000 Frm 00004 Fmt 4700 Sfmt 4700 E:\FR\FM\29OCR1.SGM 29OCR1

Federal Register / Vol. 80, No. 209 / Thursday, October 29, 2015 / Rules and Regulations 66417 Background appropriate boundary line between the Berthold Designated Area as the ‘‘Little The final and temporary regulations North Fort Berthold and South Fort Missouri River;’’ at the technical (TD 9733) that are the subject of this Berthold Designated Areas and adding conference, ONRR would like to discuss correction are under sections 954 and additional counties to one or both of the whether the Little Missouri River or the 956 of the Internal Revenue Code. two Designated Areas in the Uintah and county lines that follow the Missouri Ouray Reservation. River is the appropriate boundary Need for Correction Date And Address: ONRR will hold between the North Fort Berthold and As published, the final and temporary two sessions for the technical South Fort Berthold Designated Areas. regulations (TD 9733) contain errors that conference. The first session will be (2) ONRR found at least one Indian lease may prove to be misleading and are in held in person on November 20, 2015, that is in Wasatch County in the Uintah need of clarification. at 9:00 a.m. Mountain Time in Denver, and Ouray Reservation. In addition, Colorado. The location will be at the ONRR identified two other counties in Correction of Publication Office of Natural Resources Revenue, the Uintah and Ouray Reservation that Accordingly, the final and temporary Denver Federal Center, 6th Avenue and do not currently have Indian leases: regulations (TD 9733), that are the Kipling Street, Building 85, Carbon and Emery Counties. However subject of FR Doc. 2015–21574, are Auditoriums A–D, Denver, Colorado these Counties could have Indian leases corrected as follows: 80226. in the future. Because the current 1. On page 52977, in the preamble, The second session will be a designated areas list only includes the first column, under the paragraph teleconference on November 20, 2015, at Uintah, Duchesne, and Grand Counties heading ‘‘Background’’, the second line 2:00 p.m. Mountain Time. To call into on the Uintah and Ouray Reservation, of the paragraph, the language ‘‘to 26 the second session please call 1–866– ONRR would like to discuss adding CFR part 1 under of the Internal’’ is 778–1299, and use participant code Wasatch County to the Uintah and corrected to read ‘‘to 26 CFR part 1 5826518. Ouray—Duchesne County Designated under section 956 of the Internal’’. To RSVP for either one of these two Area. ONRR would also like to discuss 2. On page 52979, in the preamble, sessions, please email Elizabeth Dawson whether to include Carbon and Emery the second column, the first line of the at lisa.dawson@onrr.gov or call (303) Counties in either the Uintah and column, the language ‘‘the active 231–3653. Ouray—Uintah and Grand Counties or development test in §§ 1.954–’’ is If you cannot participate in either Uintah and Ouray—Duchesne County corrected to read ‘‘the active session and would like to provide Designated Areas. development test in § 1.954–’’. comments, please email us at ONRR will not consider or discuss 3. On page 52979, in the preamble, ONRRIndianOilRuleQuestions@onrr.gov other issues associated with these or the second column, the twentieth line of by November 30, 2015. other designated areas at the technical the column, the language ‘‘§§ 1.954– FOR FURTHER INFORMATION CONTACT: conference. 2T(c)(2)(iii)(E), (c)(2)(viii),’’ is corrected Elizabeth Dawson, ONRR, telephone We encourage stakeholders and to read ‘‘§ 1.954–2T(c)(2)(iii)(E), (303) 231–3653, or email at members of the public to participate in (c)(2)(viii),’’. lisa.dawson@onrr.gov. one of the two conference sessions. The 4. On page 52979, in the preamble, SUPPLEMENTARY INFORMATION: Under the conference sessions will be open to the the second column, the twelfth line new Indian oil valuation amendments public without advance registration. from the bottom of the column, the (80 FR 24794—May 1, 2015), ONRR However, attendance may be limited to language ‘‘that such rents or royalties uses designated areas to calculate index- the space available. Each attendee will that are’’ is corrected to read that such based major portion prices for lessees to be required to present a valid picture ID rents or royalties are’’. comply with the major portion in order to gain entry into the Denver provisions in their leases. Designated Federal Center and Building 85. Martin V. Franks, areas are those areas ONRR identifies as Dated: October 14, 2015. Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief unique based on their location and Gregory J. Gould, Counsel (Procedure and Administration). crude type produced from Indian lands. Director, Office of Natural Resources [FR Doc. 2015–27604 Filed 10–28–15; 8:45 am] When ONRR proposed the new Indian Revenue. oil valuation amendments (79 FR [FR Doc. 2015–27250 Filed 10–28–15; 8:45 am] BILLING CODE 4830–01–P 35102—June 19, 2014), we proposed BILLING CODE 4335–30–P sixteen initial Designated Areas. Generally, these Designated Areas were DEPARTMENT OF THE INTERIOR the Indian reservation boundaries. DEPARTMENT OF THE INTERIOR Office of Natural Resources Revenue However, there are five Designated Areas that are not the reservation National Park Service 30 CFR Parts 1206 and 1210 boundaries: Oklahoma; North Fort Berthold; South Fort Berthold; Uintah & 36 CFR Part 13 [Docket No. ONRR–2015–0002; DS63610000 Ouray: Uintah and Grand Counties; and DR2PS0000.CH7000 156D0102R2] [NPS–KLGO–19374; PPAKKLGOL0, Uintah and Ouray: Duschene County. PPMPRLE1Z.L00000] Under the new Indian Oil Valuation Technical Conference RIN 1024–AE27 Amendments—and in order to modify AGENCY: Office of Natural Resources or change an existing Designated Area— ONRR must convene a technical Special Regulations, Areas of the rmajette on DSK7SPTVN1PROD with RULES Revenue (ONRR), Interior. conference. See 30 CFR 1206.51. In National Park System, Klondike Gold ACTION: Notification of technical implementing the rule, ONRR Rush National Historical Park, Horse conference. Management discovered two potential issues: (1) The SUMMARY: ONRR will convene a preamble describes the dividing line AGENCY: National Park Service, Interior. technical conference on November 20, between the North Fort Berthold ACTION: Final rule. 2015, to discuss two issues: (1) The Designated Area and the South Fort VerDate Sep<11>2014 13:13 Oct 28, 2015 Jkt 238001 PO 00000 Frm 00005 Fmt 4700 Sfmt 4700 E:\FR\FM\29OCR1.SGM 29OCR1


Document Created: 2015-12-14 15:21:10
Document Modified: 2015-12-14 15:21:10
CategoryRegulatory Information
CollectionFederal Register
sudoc ClassAE 2.7:
GS 4.107:
AE 2.106:
PublisherOffice of the Federal Register, National Archives and Records Administration
SectionRules and Regulations
ActionFinal and temporary regulations; correction.
DatesThis correction is effective on October 29, 2015 and applicable beginning September 2, 2015.
ContactRose E. Jenkins at (202) 317-6934 (not a toll free number).
FR Citation80 FR 66416 
RIN Number1545-BJ49
2025 Federal Register | Disclaimer | Privacy Policy
USC | CFR | eCFR