81 FR 40226 - Treatment of a Certain Interests in Corporations as Stock or Indebtedness; Hearing

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 119 (June 21, 2016)

Page Range		40226-40226
FR Document		2016-14734

This document provides a notice of public hearing on proposed regulations under section 385 of the Internal Revenue Code that would authorize the Commissioner to treat certain related-party interests in a corporation as indebtedness in part and stock in part for federal tax purposes, and establish threshold documentation requirements that must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for federal tax purposes. The proposed regulations also would treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes.

Federal Register, Volume 81 Issue 119 (Tuesday, June 21, 2016)

[Federal Register Volume 81, Number 119 (Tuesday, June 21, 2016)]
[Proposed Rules]
[Page 40226]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-14734]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-108060-15]
RIN 1545-BN40


Treatment of a Certain Interests in Corporations as Stock or 
Indebtedness; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of a public hearing on notice of proposed rulemaking.

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SUMMARY: This document provides a notice of public hearing on proposed 
regulations under section 385 of the Internal Revenue Code that would 
authorize the Commissioner to treat certain related-party interests in 
a corporation as indebtedness in part and stock in part for federal tax 
purposes, and establish threshold documentation requirements that must 
be satisfied in order for certain related-party interests in a 
corporation to be treated as indebtedness for federal tax purposes. The 
proposed regulations also would treat as stock certain related-party 
interests that otherwise would be treated as indebtedness for federal 
tax purposes.

DATES: The public hearing is being held on Thursday, July 14, 2016, at 
10:00 a.m. Written or electronic comments and outlines of the topics to 
be discussed at the public hearing are still being accepted and must be 
received by July 7, 2016.

ADDRESSES: The public hearing is being held in the IRS Auditorium, 
Internal Revenue Service Building, 1111 Constitution Avenue NW., 
Washington, DC 20224. Due to building security procedures, visitors 
must enter at the Constitution Avenue entrance. In addition, all 
visitors must present photo identification to enter the building.
    Send Submissions to CC:PA:LPD:PR (REG-108060-15), Room 5205, 
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday to CC:PA:LPD:PR (REG-108060-15), Couriers Desk, Internal Revenue 
Service, 1111 Constitution Avenue NW., Washington, DC 20224 or sent 
electronically via the Federal eRulemaking Portal at 
www.regulations.gov (IRS REG-108060-15).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Austin M. Diamond-Jones at (202) 317-5363, and Raymond J. Stahl at 
(202) 317-6938; concerning submissions of comments, the hearing and/or 
to be placed on the building access list to attend the hearing Regina 
Johnson at (202) 317-6901 (not toll-free numbers).

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking (REG-108060-15) that was published in the 
Federal Register on Friday, April 8, 2016 (81 FR 20912).
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments at the hearing must submit an outline of 
the topics to be addressed and the amount of time to be devoted to each 
topic by Thursday, July 7, 2016.
    A period of 10 minutes is allotted to each person for presenting 
oral comments. After the deadline for receiving outlines has passed, 
the IRS will prepare an agenda containing the schedule of speakers. 
Copies of the agenda will be made available, free of charge, at the 
hearing or by contacting the Publications and Regulations Branch at 
(202) 317-6901 (not a toll-free number).
    Because of access restrictions, the IRS will not admit visitors 
beyond the immediate entrance area more than 30 minutes before the 
hearing starts. For information about having your name placed on the 
building access list to attend the hearing, see the FOR FURTHER 
INFORMATION CONTACT section of this document.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-14734 Filed 6-20-16; 8:45 am]
BILLING CODE 4830-01-P

40226 Federal Register / Vol. 81, No. 119 / Tuesday, June 21, 2016 / Proposed Rules

(2) An accounting of all costs of Revenue Service, P.O. Box 7604, Ben DEPARTMENT OF HOMELAND
fundraising activities; Franklin Station, Washington, DC SECURITY
(3) Supporting documentation 20044. Submissions may be hand-
showing the donations were used for delivered Monday through Friday to Coast Guard
school purposes; and CC:PA:LPD:PR (REG–108060–15),
(4) A report of the results achieved by Couriers Desk, Internal Revenue 33 CFR Part 165
use of donations. Service, 1111 Constitution Avenue NW., [Docket No. USCG–2015–0492]
Dated: June 15, 2016. Washington, DC 20224 or sent
Lawrence S. Roberts, electronically via the Federal RIN 1625–AA00
Acting Assistant Secretary—Indian Affairs. eRulemaking Portal at
Safety Zone; Lower Niagara River at
[FR Doc. 2016–14665 Filed 6–20–16; 8:45 am] www.regulations.gov (IRS REG–108060–
Niagara Falls, New York
BILLING CODE 4337–15–P 15).
AGENCY: Coast Guard, DHS.
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations, ACTION: Notice of proposed rulemaking.
DEPARTMENT OF THE TREASURY Austin M. Diamond-Jones at (202) 317– SUMMARY: The Coast Guard proposes to
Internal Revenue Service 5363, and Raymond J. Stahl at (202) establish regulations for a permanent
317–6938; concerning submissions of safety zone within the Captain of the
26 CFR Part 1 comments, the hearing and/or to be Port Zone Buffalo on the Lower Niagara
placed on the building access list to River, Niagara Falls, NY.
[REG–108060–15] attend the hearing Regina Johnson at This proposed rule is intended to
RIN 1545–BN40 (202) 317–6901 (not toll-free numbers). restrict vessels from a portion of the
SUPPLEMENTARY INFORMATION: The Lower Niagara River considered not
Treatment of a Certain Interests in navigable as listed in the United States
Corporations as Stock or subject of the public hearing is the
Coast Pilot Book 6—Great Lakes: Lake
Indebtedness; Hearing notice of proposed rulemaking (REG–
Ontario, Erie, Huron, Michigan and
108060–15) that was published in the
AGENCY: Internal Revenue Service (IRS), Superior and St. Lawrence River and
Federal Register on Friday, April 8, more specifically as described below.
Treasury. 2016 (81 FR 20912). The safety zone to be established by this
ACTION: Notice of a public hearing on
The rules of 26 CFR 601.601(a)(3) proposed rule is necessary to protect the
notice of proposed rulemaking. apply to the hearing. Persons who wish public and vessels from the hazards
SUMMARY: This document provides a to present oral comments at the hearing associated with the heavy rapids in the
notice of public hearing on proposed must submit an outline of the topics to narrow waterway of the Lower Niagara
regulations under section 385 of the be addressed and the amount of time to River.
Internal Revenue Code that would be devoted to each topic by Thursday, DATES: Comments and related materials
authorize the Commissioner to treat July 7, 2016. must be received by the Coast Guard on
certain related-party interests in a A period of 10 minutes is allotted to or before September 19, 2016.
corporation as indebtedness in part and each person for presenting oral ADDRESSES: You may submit comments
stock in part for federal tax purposes, comments. After the deadline for identified by docket number USCG–
and establish threshold documentation receiving outlines has passed, the IRS 2015–0492 using any one of the
requirements that must be satisfied in will prepare an agenda containing the following methods:
order for certain related-party interests schedule of speakers. Copies of the (1) Federal eRulemaking Portal:
in a corporation to be treated as http://www.regulations.gov.
agenda will be made available, free of
indebtedness for federal tax purposes. (2) Fax: 202–493–2251.
charge, at the hearing or by contacting
The proposed regulations also would (3) Mail: Docket Management Facility
the Publications and Regulations Branch
treat as stock certain related-party (M–30), U.S. Department of
interests that otherwise would be at (202) 317–6901 (not a toll-free
Transportation, West Building Ground
treated as indebtedness for federal tax number).
Floor, Room W12–140, 1200 New Jersey
purposes. Because of access restrictions, the IRS Avenue SE., Washington, DC 20590–
DATES: The public hearing is being held will not admit visitors beyond the 0001.
on Thursday, July 14, 2016, at 10:00 immediate entrance area more than 30 (4) Delivery: At the same as mail
a.m. Written or electronic comments minutes before the hearing starts. For address above, between 9 a.m. and 5
and outlines of the topics to be information about having your name p.m., Monday through Friday, except
discussed at the public hearing are still placed on the building access list to federal holidays. The telephone number
being accepted and must be received by attend the hearing, see the FOR FURTHER is 202–366–9329.
July 7, 2016. INFORMATION CONTACT section of this To avoid duplication, please use only
ADDRESSES: The public hearing is being document. one of these four methods. See the
held in the IRS Auditorium, Internal ‘‘Public Participation and Request for
Martin V. Franks, Comments’’ portion of the
Revenue Service Building, 1111
Chief, Publications and Regulations Branch, SUPPLEMENTARY INFORMATION section
rmajette on DSK2TPTVN1PROD with PROPOSALS

Constitution Avenue NW., Washington, Legal Processing Division, Associate Chief
DC 20224. Due to building security below for instructions on submitting
Counsel, (Procedure and Administration). comments.
procedures, visitors must enter at the [FR Doc. 2016–14734 Filed 6–20–16; 8:45 am]
Constitution Avenue entrance. In FOR FURTHER INFORMATION CONTACT: If
BILLING CODE 4830–01–P
addition, all visitors must present photo you have questions on this proposed
identification to enter the building. rule, call or email LTJG Amanda Garcia,
Send Submissions to CC:PA:LPD:PR Chief of Waterways Management, U.S.
(REG–108060–15), Room 5205, Internal Coast Guard Sector Buffalo; telephone

VerDate Sep<11>2014 14:42 Jun 20, 2016 Jkt 238001 PO 00000 Frm 00030 Fmt 4702 Sfmt 4702 E:\FR\FM\21JNP1.SGM 21JNP1

Document Created: 2016-06-21 01:30:22
Document Modified: 2016-06-21 01:30:22

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 a public hearing on notice of proposed rulemaking.
Dates		The public hearing is being held on Thursday, July 14, 2016, at 10:00 a.m. Written or electronic comments and outlines of the topics to be discussed at the public hearing are still being accepted and must be received by July 7, 2016.
Contact		Concerning the proposed regulations, Austin M. Diamond-Jones at (202) 317-5363, and Raymond J. Stahl at (202) 317-6938; concerning submissions of comments, the hearing and/or to be placed on the building access list to attend the hearing Regina Johnson at (202) 317-6901 (not toll-free numbers).
FR Citation		81 FR 40226
RIN Number		1545-BN40

81 FR 40226 - Treatment of a Certain Interests in Corporations as Stock or Indebtedness; Hearing

DEPARTMENT OF THE TREASURYInternal Revenue Service

Federal Register Volume 81, Issue 119 (June 21, 2016)

DEPARTMENT OF THE TREASURY
Internal Revenue Service