81_FR_95790 81 FR 95541 - United States Property Held by Controlled Foreign Corporations Through Partnerships With Special Allocations; Correction

81 FR 95541 - United States Property Held by Controlled Foreign Corporations Through Partnerships With Special Allocations; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 81, Issue 249 (December 28, 2016)

Page Range95541-95542
FR Document2016-31358

This document contains corrections to a notice of proposed rulemaking (REG-114734-16) that was published in the Federal Register on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations provide rules regarding the determination of the amount of the United States property treated as held by a controlled foreign corporation (CFC) through a partnership.

Federal Register, Volume 81 Issue 249 (Wednesday, December 28, 2016)
[Federal Register Volume 81, Number 249 (Wednesday, December 28, 2016)]
[Proposed Rules]
[Pages 95541-95542]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2016-31358]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-114734-16]
RIN 1545-BN51


United States Property Held by Controlled Foreign Corporations 
Through Partnerships With Special Allocations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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

SUMMARY: This document contains corrections to a notice of proposed 
rulemaking (REG-114734-16) that was published in the Federal Register 
on Thursday, November 3, 2016 (81 FR 76542). The proposed regulations 
provide rules regarding the

[[Page 95542]]

determination of the amount of the United States property treated as 
held by a controlled foreign corporation (CFC) through a partnership.

DATES: Written or electronic comments and request for a public hearing 
are still being accepted and must be received by February 1, 2017.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-114734-16), 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-
114734-16), 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-114734-16).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Rose E. Jenkins, (202) 317-6934; concerning submissions of comments or 
request for a public hearing, Regina Johnson, (202) 317-6901 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The notice of proposed rulemaking (REG-114734-16) that is the 
subject of this document is under sections 954 and 956 of the Internal 
Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-114734-16) 
contains errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the notice of proposed rulemaking, (REG-114734-16), 
that was the subject of FR Doc. 2016-26424, is corrected as follows:

0
1. On page 76543, first column, in the preamble, the sixth line from 
the top of the page, the language, ``property that does not have a 
principal'' is corrected to read ``property that is respected for 
Federal income tax purposes under section 704(b) and the regulations 
thereunder and does not have a principal''.


Sec.  1.956-4  [Corrected]

0
2. On page 76543, third column, third line from the bottom of paragraph 
(b)(2)(ii), the language ``allocation does not have a principal'' is 
corrected to read ``allocation will be respected for Federal income tax 
purposes under section 704(b) and the regulations thereunder and does 
not have a principal''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2016-31358 Filed 12-27-16; 8:45 am]
BILLING CODE 4830-01-P



                                                                      Federal Register / Vol. 81, No. 249 / Wednesday, December 28, 2016 / Proposed Rules                                               95541

                                                  caused by TSA/CAA surface treatment in                   International Branch, ANM–116, Transport              collection of information displays a current
                                                  certain bulk cargo door frame holes. Cracks              Airplane Directorate, FAA; or the European            valid OMB Control Number. The OMB
                                                  in the bulk cargo door frames can cause the              Aviation Safety Agency (EASA); or Airbus’s            Control Number for this information
                                                  in-flight loss of a bulk cargo door, damage to           EASA Design Organization Approval (DOA).              collection is 2120–0056. Public reporting for
                                                  the airplane and subsequent reduced control                                                                    this collection of information is estimated to
                                                  of the airplane.                                         (j) Terminating Action
                                                                                                                                                                 be approximately 5 minutes per response,
                                                                                                              Accomplishment of a repair on an airplane,         including the time for reviewing instructions,
                                                  (f) Compliance                                           as required by paragraph (i) of this AD, does         completing and reviewing the collection of
                                                     Comply with this AD within the                        not constitute terminating action for the             information. All responses to this collection
                                                  compliance times specified, unless already               inspections required by this AD for that              of information are mandatory. Comments
                                                  done.                                                    airplane, unless otherwise specified in repair        concerning the accuracy of this burden and
                                                                                                           instructions approved by the Manager,                 suggestions for reducing the burden should
                                                  (g) Initial Inspection                                   International Branch, ANM–116, Transport              be directed to the FAA at: 800 Independence
                                                     At the applicable compliance time                     Airplane Directorate, FAA; or EASA; or                Ave. SW., Washington, DC 20591, Attn:
                                                  specified in table 1 to paragraph (g) of this            Airbus’s EASA DOA.                                    Information Collection Clearance Officer,
                                                  AD, do the actions specified in paragraph                                                                      AES–200.
                                                  (g)(1) or (g)(2) of this AD, in accordance with          (k) Reporting
                                                  the instructions of Airbus Alert Operators                  After the initial inspection specified in          (m) Related Information
                                                  Transmission (AOT), AOT A53L012–16,                      paragraph (g) of this AD, and after each                (1) Refer to Mandatory Continuing
                                                  Revision 00, dated May 30, 2016.                         repetitive inspection specified in paragraph          Airworthiness Information (MCAI) EASA AD
                                                     (1) Accomplish a rototest inspection to               (h) of this AD, at the applicable times               2016–0102, dated June 1, 2016; corrected
                                                  detect cracking of the holes for the bulk cargo          specified in paragraph (k)(1) and (k)(2) of this      June 7, 2016, for related information. You
                                                  door support fittings at fuselage frame (FR)             AD: Report inspection findings, both positive         may examine the MCAI on the Internet at
                                                  67 and FR 69, and a high-frequency eddy-                 and negative, to Airbus in accordance with            http://www.regulations.gov by searching for
                                                  current (HFEC) inspection of the holes for the           the instructions of Airbus AOT A53L012–16,            and locating Docket No. FAA–2016–9517.
                                                  door latch fitting at FR 69.                             Revision 00, dated May 30, 2016.                        (2) For service information identified in
                                                     (2) Accomplish a detailed visual inspection              (1) If the inspection was done on or after         this AD, contact Airbus SAS, Airworthiness
                                                  to detect cracking in the bulk cargo door                the effective date of this AD: Submit the
                                                                                                                                                                 Office—EAL, 1 Rond Point Maurice Bellonte,
                                                  support fittings at FR 67 and FR 69 and the              report within 30 days after the inspection.
                                                                                                                                                                 31707 Blagnac Cedex, France; telephone +33
                                                  holes for the door latch fitting at FR 69.                  (2) If the inspection was done before the
                                                                                                                                                                 5 61 93 36 96; fax +33 5 61 93 45 80; email
                                                                                                           effective date of this AD: Submit the report
                                                                                                                                                                 airworthiness.A330-A340@airbus.com;
                                                    TABLE 1 TO PARAGRAPH (g) OF THIS                       within 30 days after the effective date of this
                                                                                                                                                                 Internet http://www.airbus.com. You may
                                                                                                           AD.
                                                         AD—INITIAL INSPECTION                                                                                   view this service information at the FAA,
                                                                                                           (l) Other FAA AD Provisions                           Transport Airplane Directorate, 1601 Lind
                                                      Total flight cycles                                     The following provisions also apply to this        Avenue SW., Renton, WA. For information
                                                     accumulated since                                     AD:                                                   on the availability of this material at the
                                                   airplane first flight, on     Compliance time                                                                 FAA, call 425–227–1221.
                                                    the effective date of                                     (1) Alternative Methods of Compliance
                                                           this AD                                         (AMOCs): The Manager, International                     Issued in Renton, Washington, on
                                                                                                           Branch, ANM–116, Transport Airplane                   December 2, 2016.
                                                  12,500 total flight cy-      Within 200 flight cy-       Directorate, FAA, has the authority to                Michael Kaszycki,
                                                    cles or more.               cles or 2 months,          approve AMOCs for this AD, if requested
                                                                                                           using the procedures found in 14 CFR 39.19.           Acting Manager, Transport Airplane
                                                                                whichever occurs                                                                 Directorate, Aircraft Certification Service.
                                                                                first, after the effec-    In accordance with 14 CFR 39.19, send your
                                                                                tive date of this AD.      request to your principal inspector or local          [FR Doc. 2016–30611 Filed 12–27–16; 8:45 am]
                                                  Fewer than 12,500            Within 200 flight cy-       Flight Standards District Office, as                  BILLING CODE 4910–13–P
                                                    total flight cycles.        cles or 2 months,          appropriate. If sending information directly
                                                                                whichever occurs           to the International Branch, send it to ATTN:
                                                                                first, after exceed-       Vladimir Ulyanov, Aerospace Engineer,
                                                                                                           International Branch, ANM–116, Transport              DEPARTMENT OF THE TREASURY
                                                                                ing 12,500 flight cy-
                                                                                cles.                      Airplane Directorate, FAA, 1601 Lind
                                                                                                           Avenue SW., Renton, WA 98057–3356;                    Internal Revenue Service
                                                                                                           telephone 425–227–1138; fax 425–227–1149.
                                                  (h) Repetitive Inspections
                                                                                                           Information may be emailed to: 9-ANM-116-             26 CFR Part 1
                                                    At intervals not to exceed the values                  AMOC-REQUESTS@faa.gov. Before using
                                                  specified in table 2 to paragraph (h) of this            any approved AMOC, notify your appropriate            [REG–114734–16]
                                                  AD, as applicable, depending on the                      principal inspector, or lacking a principal
                                                  previously selected inspection method,                   inspector, the manager of the local flight            RIN 1545–BN51
                                                  repeat the inspection(s) specified in either             standards district office/certificate holding
                                                  paragraph (g)(1) or (g)(2) of this AD.                   district office. The AMOC approval letter             United States Property Held by
                                                                                                           must specifically reference this AD.                  Controlled Foreign Corporations
                                                    TABLE 2 TO PARAGRAPH (h) OF THIS                          (2) Contacting the Manufacturer: For any           Through Partnerships With Special
                                                      AD—REPETITIVE INSPECTIONS                            requirement in this AD to obtain corrective           Allocations; Correction
                                                                                                           actions from a manufacturer, the action must
                                                                                                           be accomplished using a method approved               AGENCY:  Internal Revenue Service (IRS),
                                                    Inspection method            Inspection interval                                                             Treasury.
                                                                                                           by the Manager, International Branch, ANM–
                                                  Detailed visual in-          150 flight cycles.          116, Transport Airplane Directorate, FAA; or          ACTION: Correction to a notice of
                                                                                                           EASA; or Airbus’s EASA DOA. If approved
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                                                    spection.                                                                                                    proposed rulemaking.
                                                  Rototest and HFEC            2,900 flight cycles.        by the DOA, the approval must include the
                                                    inspections.                                           DOA-authorized signature.                             SUMMARY:  This document contains
                                                                                                              (3) Reporting Requirements: A federal              corrections to a notice of proposed
                                                                                                           agency may not conduct or sponsor, and a
                                                  (i) Repair                                               person is not required to respond to, nor
                                                                                                                                                                 rulemaking (REG–114734–16) that was
                                                     If, during any inspection required by                 shall a person be subject to a penalty for            published in the Federal Register on
                                                  paragraph (g) or (h) of this AD, any crack is            failure to comply with a collection of                Thursday, November 3, 2016 (81 FR
                                                  detected, before further flight, repair using a          information subject to the requirements of            76542). The proposed regulations
                                                  method approved by the Manager,                          the Paperwork Reduction Act unless that               provide rules regarding the


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                                                  95542             Federal Register / Vol. 81, No. 249 / Wednesday, December 28, 2016 / Proposed Rules

                                                  determination of the amount of the                      thereunder and does not have a                        on the submission): Regulations
                                                  United States property treated as held                  principal’’.                                          Comments Desk (External Policy
                                                  by a controlled foreign corporation                                                                           Program, Strategy and Performance
                                                                                                          Martin V. Franks,
                                                  (CFC) through a partnership.                                                                                  Division (SP)); Suite 4100; National
                                                                                                          Chief, Publications and Regulations Branch,
                                                  DATES: Written or electronic comments                                                                         Archives and Records Administration;
                                                                                                          Legal Processing Division, Associate Chief
                                                  and request for a public hearing are still              Counsel, (Procedure and Administration).              8601 Adelphi Road; College Park, MD
                                                  being accepted and must be received by                                                                        20740–6001
                                                                                                          [FR Doc. 2016–31358 Filed 12–27–16; 8:45 am]
                                                  February 1, 2017.                                                                                                • Hand delivery or courier: Deliver
                                                                                                          BILLING CODE 4830–01–P
                                                                                                                                                                comments to the front desk at the
                                                  ADDRESSES:   Send submissions to:                                                                             address above.
                                                  CC:PA:LPD:PR (REG–114734–16), Room                                                                               Instructions: You must include on all
                                                  5203, Internal Revenue Service, P.O.                    NATIONAL ARCHIVES AND RECORDS                         submissions the Regulatory Information
                                                  Box 7604, Ben Franklin Station,                         ADMINISTRATION                                        Number (RIN) for this rulemaking (RIN
                                                  Washington, DC 20044. Submissions                                                                             3095–AB87) and NARA’s name. We
                                                  may be hand-delivered Monday through                    36 CFR Part 1270
                                                                                                                                                                may publish any comments we receive
                                                  Friday between the hours of 8 a.m. and                  [FDMS No. NARA–16–0005; NARA–2017–                    without changes, including any
                                                  4 p.m. to CC:PA:LPD:PR (REG–114734–                     011]                                                  personal information you provide.
                                                  16), Courier’s Desk, Internal Revenue                   RIN 3095–AB87                                         FOR FURTHER INFORMATION CONTACT:
                                                  Service, 1111 Constitution Avenue NW.,                                                                        Kimberly Keravuori, by email at
                                                  Washington, DC, or sent electronically                  Presidential Records                                  regulation_comments@nara.gov, or by
                                                  via the Federal eRulemaking Portal at                                                                         telephone at 301–837–3151.
                                                  http://www.regulations.gov (IRS REG–                    AGENCY:  National Archives and Records
                                                                                                          Administration (NARA).                                SUPPLEMENTARY INFORMATION:
                                                  114734–16).
                                                                                                          ACTION: Proposed rule.                                Background
                                                  FOR FURTHER INFORMATION CONTACT:
                                                  Concerning the proposed regulations,                    SUMMARY:   We are proposing to revise                    We are revising our regulations
                                                  Rose E. Jenkins, (202) 317–6934;                        this regulation to reflect changes                    governing Presidential and Vice
                                                  concerning submissions of comments or                   instituted by the Presidential and                    Presidential records to incorporate
                                                  request for a public hearing, Regina                    Federal Records Acts Amendments of                    changes made by the Presidential and
                                                  Johnson, (202) 317–6901 (not a toll-free                2014 (2014 Amendments). These                         Federal Records Act Amendments of
                                                  number).                                                Amendments in part added new                          2014, (‘‘2014 Amendments,’’ Pub. L.
                                                  SUPPLEMENTARY INFORMATION:                              requirements to the Presidential Records              113–187, 128 Stat. 1017).
                                                                                                          Act (PRA), which went into effect in                     The 2014 Amendments made several
                                                  Background                                              2014 and remain in effect, even without               changes to the Presidential Records Act
                                                                                                          this proposed regulatory revision. The                (44 U.S.C. 2201–2209). The most
                                                    The notice of proposed rulemaking
                                                                                                          proposed changes make clear that, when                substantial change was codifying the
                                                  (REG–114734–16) that is the subject of
                                                                                                          we maintain electronic Presidential                   procedures by which we notify former
                                                  this document is under sections 954 and
                                                                                                          records on behalf of the President before             and incumbent Presidents so that they
                                                  956 of the Internal Revenue Code.
                                                                                                          the President’s term of office expires,               may consider whether to restrict public
                                                  Need for Correction                                     the President retains exclusive control               access to Presidential records of former
                                                                                                          over the records. In addition, the                    Presidents that are in our legal custody.
                                                    As published, the notice of proposed
                                                                                                          proposed changes establish procedures                 This privilege review process was
                                                  rulemaking (REG–114734–16) contains
                                                                                                          that we will follow to notify an                      previously controlled by an Executive
                                                  errors that may prove to be misleading
                                                                                                          incumbent President and former                        Order, subject to change by any sitting
                                                  and are in need of clarification.
                                                                                                          President when we propose to disclose                 administration. Because Congress
                                                  Correction of Publication                               Presidential records to the public,                   codified the privilege review process for
                                                                                                          Congress, the courts, or the incumbent                public disclosures in the 2014
                                                    Accordingly, the notice of proposed                   President under the provisions of the                 Amendments, we are revising the
                                                  rulemaking, (REG–114734–16), that was                   PRA allowing for access to Presidential               regulation to set out processes for giving
                                                  the subject of FR Doc. 2016–26424, is                   records otherwise subject to restrictions.            notice in such cases, and for former or
                                                  corrected as follows:                                   We began the regulatory revision                      incumbent Presidents to consider
                                                  ■ 1. On page 76543, first column, in the                process in response to the 2014                       whether to assert a constitutionally
                                                  preamble, the sixth line from the top of                Amendments and issue this updated                     based privilege.
                                                  the page, the language, ‘‘property that                 regulation to reduce confusion about                     The 2014 Amendments did not codify
                                                  does not have a principal’’ is corrected                access to Presidential records in light of            the provisions of the Executive Order
                                                  to read ‘‘property that is respected for                these recent changes in the law.                      allowing for notification to the former
                                                  Federal income tax purposes under                       DATES: Submit comments by January 27,                 and incumbent President when
                                                  section 704(b) and the regulations                      2017.                                                 Congress, the courts, or the incumbent
                                                  thereunder and does not have a                          ADDRESSES: You may submit comments,                   President (instead of the public) makes
                                                  principal’’.                                            identified by RIN 3095–AB87, by any of                the request for records subject to access
                                                                                                                                                                restrictions. To ensure that the former
sradovich on DSK3GMQ082PROD with PROPOSALS




                                                  § 1.956–4   [Corrected]                                 the following methods:
                                                                                                            • Federal eRulemaking Portal: http://               and incumbent Presidents are given
                                                  ■ 2. On page 76543, third column, third                 www.regulations.gov. Follow the                       notice and an opportunity to consider
                                                  line from the bottom of paragraph                       instructions for submitting comments.                 whether to assert a constitutionally
                                                  (b)(2)(ii), the language ‘‘allocation does                • Email: Regulation_comments@                       based privilege in those circumstances
                                                  not have a principal’’ is corrected to                  nara.gov. Include RIN 3095–AB87 in the                as well, we are revising our regulation
                                                  read ‘‘allocation will be respected for                 subject line of the message.                          to set out procedures we follow prior to
                                                  Federal income tax purposes under                         • Mail (for paper, disk, or CD–ROM                  disclosing records under the PRA’s
                                                  section 704(b) and the regulations                      submissions. Include RIN 3095–AB87                    exceptions to restricted access, which


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Document Created: 2016-12-28 02:17:04
Document Modified: 2016-12-28 02:17:04
CategoryRegulatory Information
CollectionFederal Register
sudoc ClassAE 2.7:
GS 4.107:
AE 2.106:
PublisherOffice of the Federal Register, National Archives and Records Administration
SectionProposed Rules
ActionCorrection to a notice of proposed rulemaking.
DatesWritten or electronic comments and request for a public hearing are still being accepted and must be received by February 1, 2017.
ContactConcerning the proposed regulations, Rose E. Jenkins, (202) 317-6934; concerning submissions of comments or request for a public hearing, Regina Johnson, (202) 317-6901 (not a toll-free number).
FR Citation81 FR 95541 
RIN Number1545-BN51

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