81_FR_64242 81 FR 64061 - Country-by-Country Reporting; Correction

81 FR 64061 - Country-by-Country Reporting; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 181 (September 19, 2016)

Page Range64061-64061
FR Document2016-22440

This document contains corrections to final regulations (TD 9773) that were published in the Federal Register on Thursday, June 30, 2016 (81 FR 42482). This document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.

Federal Register, Volume 81 Issue 181 (Monday, September 19, 2016)
[Federal Register Volume 81, Number 181 (Monday, September 19, 2016)]
[Rules and Regulations]
[Page 64061]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-22440]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9773]
RIN 1545-BM70


Country-by-Country Reporting; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final regulations (TD 
9773) that were published in the Federal Register on Thursday, June 30, 
2016 (81 FR 42482). This document contains final regulations that 
require annual country-by-country reporting by certain United States 
persons that are the ultimate parent entity of a multinational 
enterprise group.

DATES: This correction is effective September 19, 2016 and is 
applicable on or after June 30, 2016.

FOR FURTHER INFORMATION CONTACT: Melinda E. Harvey of the Office of 
Associate Chief Counsel (International) at (202) 317-6934 (not a toll-
free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9773) that are the subject of this 
correction are under section 1.6038-4 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations (TD 9773) contain errors that 
may prove to be misleading and are in need of clarification.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

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

0
Par. 2. Section 1.6038-4 is amended by revising paragraph (d)(3)(iv) to 
read as follows:


Sec.  1.6038-4  Information returns required of certain United States 
persons with respect to such person's U.S. multinational enterprise 
group.

* * * * *
    (d) * * *
    (3) * * *
    (iv) Income tax paid and accrued tax expense of permanent 
establishment. In the case of a constituent entity that is a permanent 
establishment, the amount of income tax paid and the amount of accrued 
tax expense referred to in paragraphs (d)(2)(iv) and (v) of this 
section should not include the income tax paid or tax expense accrued 
by the business entity of which the permanent establishment would be a 
part, but for the third sentence of paragraph (b)(2) of this section, 
in that business entity's tax jurisdiction of residence on the income 
derived by the permanent establishment.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-22440 Filed 9-16-16; 8:45 am]
 BILLING CODE 4830-01-P



                                                              Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Rules and Regulations                                      64061

                                             (preventive controls for animal food                    Associate Chief Counsel (International)               DEPARTMENT OF DEFENSE
                                             rule). In § 507.3, we included the                      at (202) 317–6934 (not a toll-free
                                             definition of a qualified auditor. In the               number).                                              Office of the Secretary
                                             definition, we provided examples of
                                                                                                     SUPPLEMENTARY INFORMATION:                            32 CFR Part 66
                                             qualified auditors. Paragraph 2 of the
                                             definition reads ‘‘An audit agent of a                  Background                                            [Docket ID: DOD–2011–OS–0099]
                                             certification body that is accredited in
                                             accordance with regulations in part 1,                    The final regulations (TD 9773) that                RIN 0790–AI78
                                             subpart M of this chapter.’’ At the time                are the subject of this correction are
                                             the final rule published, paragraph 2                   under section 1.6038–4 of the Internal                Qualification Standards for Enlistment,
                                             referred to a provision in a future final               Revenue Code.                                         Appointment, and Induction
                                             rule: ‘‘Accreditation of Third-Party                    Need for Correction                                   AGENCY:  Office of the Under Secretary of
                                             Certification Bodies to Conduct Food                                                                          Defense for Personnel and Readiness,
                                             Safety Audits to Issue Certifications’’                   As published, the final regulations                 DoD.
                                             (third-party certification rule). In the                (TD 9773) contain errors that may prove
                                                                                                                                                           ACTION: Final rule.
                                             preamble to the preventive controls for                 to be misleading and are in need of
                                             animal food rule, we stated that we                     clarification.                                        SUMMARY:   This rule updates policies and
                                             would publish a document in the                         List of Subjects in 26 CFR Part 1                     responsibilities for basic entrance
                                             Federal Register announcing the                                                                               qualification standards for enlistment,
                                             effective date of paragraph (2) once we                   Income taxes, Reporting and                         appointment, and induction into the
                                             finalized the third-party certification                 recordkeeping requirements.                           Armed Forces and delegates the
                                             rule (80 FR 55908 at 55954).                                                                                  authority to specify certain standards to
                                                The final third-party certification rule             Correction of Publication
                                                                                                                                                           the Secretaries of the Military
                                             (80 FR 74569) published in the Federal                    Accordingly, 26 CFR part 1 is                       Departments. It establishes the age,
                                             Register on November 27, 2015, with an                  corrected by making the following                     aptitude, character/conduct, citizenship,
                                             effective date of January 26, 2016. This                correcting amendments:                                dependents, education, medical,
                                             document announces that the effective                                                                         physical fitness, and other disqualifying
                                             date for paragraph 2 in the definition of               PART 1—INCOME TAXES                                   conditions that are causes for rejection
                                             qualified auditor in § 117.3 (80 FR                                                                           from military service. Other standards
                                             55098 at 56147) and § 507.3 (80 FR                      ■ Paragraph 1. The authority citation                 may be prescribed in the event of
                                             56170 at 56339) is September 19, 2016.                  for part 1 continues to read in part as               mobilization or national emergency.
                                               Dated: September 14, 2016.                            follows:                                              This rule sets standards designed to
                                             Leslie Kux,                                                 Authority: 26 U.S.C. 7805 * * *                   ensure that individuals under
                                             Associate Commissioner for Policy.                      ■ Par. 2. Section 1.6038–4 is amended                 consideration for enlistment,
                                             [FR Doc. 2016–22494 Filed 9–16–16; 8:45 am]             by revising paragraph (d)(3)(iv) to read              appointment, and/or induction are able
                                             BILLING CODE 4164–01–P                                  as follows:                                           to perform military duties successfully,
                                                                                                                                                           and to select those who are the most
                                                                                                     § 1.6038–4 Information returns required of            suitable for Service life.
                                                                                                     certain United States persons with respect            DATES: Effective Date: This rule is
                                             DEPARTMENT OF THE TREASURY                              to such person’s U.S. multinational                   effective on October 19, 2016.
                                                                                                     enterprise group.
                                             Internal Revenue Service                                                                                      FOR FURTHER INFORMATION CONTACT:
                                                                                                     *     *     *     *     *                             Dennis J. Drogo, (703) 697–9268.
                                             26 CFR Part 1                                             (d) * * *                                           SUPPLEMENTARY INFORMATION:
                                             [TD 9773]                                                 (3) * * *
                                                                                                       (iv) Income tax paid and accrued tax                Public Comments and Responses
                                             RIN 1545–BM70                                                                                                    On March 27, 2015 (80 FR 16269–
                                                                                                     expense of permanent establishment. In
                                             Country-by-Country Reporting;                           the case of a constituent entity that is a            16277), the Department of Defense
                                             Correction                                              permanent establishment, the amount of                published an interim final rule titled
                                                                                                     income tax paid and the amount of                     ‘‘Qualification Standards for Enlistment,
                                             AGENCY:  Internal Revenue Service (IRS),                accrued tax expense referred to in                    Appointment, and Induction’’ for a 60-
                                             Treasury.                                               paragraphs (d)(2)(iv) and (v) of this                 day public comment period. The
                                             ACTION: Correcting amendment.                           section should not include the income                 comment period ended on May 26,
                                                                                                     tax paid or tax expense accrued by the                2015. Three public comments were
                                             SUMMARY:   This document contains                       business entity of which the permanent                received. This section addresses those
                                             corrections to final regulations (TD                    establishment would be a part, but for                comments.
                                             9773) that were published in the                        the third sentence of paragraph (b)(2) of                Comment 1: ‘‘Abstain: the area were
                                             Federal Register on Thursday, June 30,                  this section, in that business entity’s tax           I live is not for emergency personnel
                                             2016 (81 FR 42482). This document                       jurisdiction of residence on the income               conducting business that should be
                                             contains final regulations that require                 derived by the permanent                              known as unwanted security.’’
                                             annual country-by-country reporting by                  establishment.                                           Response: The Department of Defense
                                             certain United States persons that are                                                                        thanks the commenter for the comment.
                                             the ultimate parent entity of a                         *     *     *     *     *
rmajette on DSK2TPTVN1PROD with RULES




                                                                                                                                                           No changes were made to the final rule
                                             multinational enterprise group.                         Martin V. Franks,                                     as a result.
                                             DATES: This correction is effective                     Chief, Publications and Regulations Branch,              Comment 2: A 16-year veteran of the
                                             September 19, 2016 and is applicable on                 Legal Processing Division, Associate Chief            Air Force is in favor of having a
                                             or after June 30, 2016.                                 Counsel, (Procedure and Administration).              qualified Armed Service to serve our
                                             FOR FURTHER INFORMATION CONTACT:                        [FR Doc. 2016–22440 Filed 9–16–16; 8:45 am]           country but, the commenter thinks
                                             Melinda E. Harvey of the Office of                      BILLING CODE 4830–01–P                                interviews should be a part of the


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Document Created: 2016-09-17 02:30:38
Document Modified: 2016-09-17 02:30:38
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
ActionCorrecting amendment.
DatesThis correction is effective September 19, 2016 and is applicable on or after June 30, 2016.
ContactMelinda E. Harvey of the Office of Associate Chief Counsel (International) at (202) 317-6934 (not a toll- free number).
FR Citation81 FR 64061 
RIN Number1545-BM70
CFR AssociatedIncome Taxes and Reporting and Recordkeeping Requirements

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