82 FR 15102 - Proposed Collection; Comment Request for Regulation Project

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 82, Issue 56 (March 24, 2017)

Page Range		15102-15103
FR Document		2017-05832

The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995. Currently, the IRS is soliciting comments concerning treatment of dual consolidated losses.

Federal Register, Volume 82 Issue 56 (Friday, March 24, 2017)

[Federal Register Volume 82, Number 56 (Friday, March 24, 2017)]
[Notices]
[Pages 15102-15103]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2017-05832]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Regulation Project

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: The Department of the Treasury, as part of its continuing 
effort to reduce paperwork and respondent burden, invites the general 
public and other Federal agencies to take this opportunity to comment 
on proposed and/or continuing information collections, as required by 
the Paperwork Reduction Act of 1995. Currently, the IRS is soliciting

[[Page 15103]]

comments concerning treatment of dual consolidated losses.

DATES: Written comments should be received on or before May 23, 2017 to 
be assured of consideration.

ADDRESSES: Direct all written comments to Laurie Brimmer, Internal 
Revenue Service, Room 6526, 1111 Constitution Avenue NW., Washington, 
DC 20224.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the regulations should be directed to Kerry Dennis at 
Internal Revenue Service, 1111 Constitution Avenue NW., Room 6526, 
Washington, DC 20224, or through the internet at [email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Treatment of Dual Consolidated Losses.
    OMB Number: 1545-1083.
    Regulation Project Number: TD 8434.
    Abstract: Internal Revenue Code section 1503(d) denies use of the 
losses of one domestic corporation by another affiliated domestic 
corporation where the loss corporation is also subject to the income 
tax of another country. This regulation allows an affiliate to make use 
of the loss if the loss has not been used in the foreign country and if 
an agreement is attached to the income tax return of the dual resident 
corporation or group, to take the loss into income upon future use of 
the loss in the foreign country. The regulation also requires separate 
accounting for a dual consolidated loss where the dual resident 
corporation files a consolidated return.
    Current Actions: There is no change to this existing regulation.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Business or other for-profit organizations.
    Estimated Number of Respondents: 500.
    Estimated Number of Responses: 896.
    Estimated Time per Response: 1 hr., 49 minutes.
    Estimated Total Annual Burden Hours: 1,620.
    The following paragraph applies to all of the collections of 
information covered by this notice:
    An agency may not conduct or sponsor, and a person is not required 
to respond to, a collection of information unless the collection of 
information displays a valid OMB control number. Books or records 
relating to a collection of information must be retained as long as 
their contents may become material in the administration of any 
internal revenue law. Generally, tax returns and tax return information 
are confidential, as required by 26 U.S.C. 6103.
    Request for Comments: Comments submitted in response to this notice 
will be summarized and/or included in the request for OMB approval. All 
comments will become a matter of public record. Comments are invited 
on: (a) Whether the collection of information is necessary for the 
proper performance of the functions of the agency, including whether 
the information shall have practical utility; (b) the accuracy of the 
agency's estimate of the burden of the collection of information; (c) 
ways to enhance the quality, utility, and clarity of the information to 
be collected; (d) ways to minimize the burden of the collection of 
information on respondents, including through the use of automated 
collection techniques or other forms of information technology; and (e) 
estimates of capital or start-up costs and costs of operation, 
maintenance, and purchase of services to provide information.

    Approved: March 16, 2017.
Laurie Brimmer,
IRS Tax Analyst.
[FR Doc. 2017-05832 Filed 3-23-17; 8:45 am]
 BILLING CODE 4830-01-P

15102 Federal Register / Vol. 82, No. 56 / Friday, March 24, 2017 / Notices

Type of Review: Revision of a SUMMARY: The department of the The following paragraph applies to all
currently approved collection. Treasury, as part of its continuing effort of the collections of information covered
Affected Public: Individuals, business to reduce paperwork and respondent by this notice.
or other for-profit organizations, not-for- burden, invites the general public and An agency may not conduct or
profit institutions, and Federal, state, other Federal agencies to take this sponsor, and a person is not required to
local or tribal governments. opportunity to comment on proposed respond to, a collection of information
Estimated Number of Respondents: and/or continuing information unless the collection of information
1,125. collections, as required by the displays a valid OMB control number.
Estimated Time per Respondent: 1.25 Paperwork Reduction Act of 1995, Books or records relating to a collection
hours. Public Law 104–13(44 U.S.C. of information must be retained as long
Estimated Total Annual Burden 3506(c)(2)(A)). Currently, the IRS is as their contents may become material
Hours: 1,406.25. soliciting comments concerning unified
The following paragraph applies to all in the administration of any internal
rule for loss on subsidiary stock. revenue law. Generally, tax returns and
of the collections of information covered
by this notice. DATES: Written comments should be tax return information are confidential,
An agency may not conduct or received on or before May 23, 2017 to as required by 26 U.S.C. 6103.
sponsor, and a person is not required to be assured of consideration. Request for Comments: Comments
respond to, a collection of information ADDRESSES: Direct all written comments submitted in response to this notice will
unless the collection of information to Laurie Brimmer, Internal Revenue be summarized and/or included in the
displays a valid OMB control number. Service, Room 6526, 1111 Constitution request for OMB approval. All
Books or records relating to a collection Avenue NW., Washington, DC 20224. comments will become a matter of
of information must be retained as long public record. Comments are invited on:
FOR FURTHER INFORMATION CONTACT:
as their contents may become material (a) Whether the collection of
Requests for additional information or
in the administration of any internal information is necessary for the proper
copies of the regulation should be
revenue law. Generally, tax returns and performance of the functions of the
directed to Kerry Dennis at Internal
tax return information are confidential, agency, including whether the
Revenue Service, Room 6526, 1111
as required by 26 U.S.C. 6103. information shall have practical utility;
Constitution Avenue NW., Washington,
Request for Comments: Comments (b) the accuracy of the agency’s estimate
DC 20224, or through the internet, at
submitted in response to this notice will of the burden of the collection of
Kerry.Dennis@irs.gov .
be summarized and/or included in the information; (c) ways to enhance the
request for OMB approval. All SUPPLEMENTARY INFORMATION: quality, utility, and clarity of the
comments will become a matter of Title: Unified Rule for Loss on information to be collected; (d) ways to
public record. Comments are invited on: Subsidiary Stock. minimize the burden of the collection of
(a) Whether the collection of OMB Number: 1545–2096. information on respondents, including
information is necessary for the proper Regulation Project Number: REG– through the use of automated collection
performance of the functions of the 157711–02 (TD 9424—final). techniques or other forms of information
agency, including whether the Abstract: This document contains technology; and (e) estimates of capital
information shall have practical utility; final regulations under sections 358, or start-up costs and costs of operation,
(b) the accuracy of the agency’s estimate 362(e)(2), and 1502 of the Internal maintenance, and purchase of services
of the burden of the collection of Revenue Code (Code). The regulations to provide information.
information; (c) ways to enhance the apply to corporations filing
Approved: March 16, 2017.
quality, utility, and clarity of the consolidated returns, and corporations
Laurie Brimmer,
information to be collected; (d) ways to that enter into certain tax-free
minimize the burden of the collection of reorganizations. The regulations provide IRS Tax Analyst.
information on respondents, including rules for determining the tax [FR Doc. 2017–05831 Filed 3–23–17; 8:45 am]
through the use of automated collection consequences of a member’s transfer BILLING CODE 4830–01–P
techniques or other forms of information (including by deconsolidation and
technology; and (e) estimates of capital worthlessness) of loss shares of
or start-up costs and costs of operation, subsidiary stock. In addition, the DEPARTMENT OF THE TREASURY
maintenance, and purchase of services regulations provide that section
Internal Revenue Service
to provide information. 362(e)(2) generally does not apply to
Approved: March 16, 2017. transactions between members of a Proposed Collection; Comment
Laurie Brimmer, consolidated group. Finally, the Request for Regulation Project
regulations conform or clarify various
IRS Tax Analyst.
provisions of the consolidated return AGENCY: Internal Revenue Service (IRS),
[FR Doc. 2017–05833 Filed 3–23–17; 8:45 am]
regulations, including those relating to Treasury.
BILLING CODE 4830–01–P
adjustments to subsidiary stock basis. ACTION: Notice and request for
Current Actions: There is no change to comments.
DEPARTMENT OF THE TREASURY this existing regulation.
Type of Review: Extension of a SUMMARY: The Department of the
Internal Revenue Service currently approved collection. Treasury, as part of its continuing effort
Affected Public: Business or other for- to reduce paperwork and respondent
jstallworth on DSK7TPTVN1PROD with NOTICES

Proposed Collection: Comment profit organizations. burden, invites the general public and
Request for Regulation Project Estimated Number of Respondents: other Federal agencies to take this
AGENCY: Internal Revenue Service (IRS), 100. opportunity to comment on proposed
Treasury. Estimated Time per Respondent: 15 and/or continuing information
minutes. collections, as required by the
ACTION: Notice and request for
Estimated Total Annual Burden Paperwork Reduction Act of 1995.
comments.
Hours: 25. Currently, the IRS is soliciting

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Federal Register / Vol. 82, No. 56 / Friday, March 24, 2017 / Notices 15103

comments concerning treatment of dual Request for Comments: Comments Constitution Avenue NW., Washington,
consolidated losses. submitted in response to this notice will DC 20224, or through the Internet at
DATES: Written comments should be be summarized and/or included in the Kerry.Dennis@irs.gov.
received on or before May 23, 2017 to request for OMB approval. All SUPPLEMENTARY INFORMATION:
be assured of consideration. comments will become a matter of Title: Certain Transfers of Domestic
ADDRESSES: Direct all written comments public record. Comments are invited on: Stock or Securities by U.S. Persons to
to Laurie Brimmer, Internal Revenue (a) Whether the collection of Foreign Corporations.
Service, Room 6526, 1111 Constitution information is necessary for the proper OMB Number: 1545–1478.
Avenue NW., Washington, DC 20224. performance of the functions of the Regulation Project Number: INTL–9–
agency, including whether the 95 (TD 8702).
FOR FURTHER INFORMATION CONTACT:
information shall have practical utility; Abstract: This regulation relates to
Requests for additional information or
(b) the accuracy of the agency’s estimate certain transfers of stock or securities of
copies of the regulations should be
of the burden of the collection of domestic corporations pursuant to the
directed to Kerry Dennis at Internal
information; (c) ways to enhance the corporate organization, reorganization,
Revenue Service, 1111 Constitution
quality, utility, and clarity of the or liquidation provisions of the internal
Avenue NW., Room 6526, Washington,
information to be collected; (d) ways to Revenue Code. Transfers of stock or
DC 20224, or through the internet at
minimize the burden of the collection of securities by U.S. persons in tax-free
Kerry.Dennis@irs.gov.
information on respondents, including transactions are treated as taxable
SUPPLEMENTARY INFORMATION: through the use of automated collection
Title: Treatment of Dual Consolidated transactions when the acquirer is a
techniques or other forms of information foreign corporation, unless an exception
Losses. technology; and (e) estimates of capital
OMB Number: 1545–1083. applies under Code section 367(a). This
or start-up costs and costs of operation, regulation provides that no U.S. person
Regulation Project Number: TD 8434.
maintenance, and purchase of services will qualify for an exception unless the
Abstract: Internal Revenue Code
to provide information. U.S. target company complies with
section 1503(d) denies use of the losses
of one domestic corporation by another Approved: March 16, 2017. certain reporting requirements.
affiliated domestic corporation where Laurie Brimmer, Current Actions: There is no change to
the loss corporation is also subject to the IRS Tax Analyst. this existing regulation.
income tax of another country. This [FR Doc. 2017–05832 Filed 3–23–17; 8:45 am] Type of Review: Extension of a
regulation allows an affiliate to make BILLING CODE 4830–01–P
currently approved collection.
use of the loss if the loss has not been Affected Public: Business or other for-
used in the foreign country and if an profit organizations.
agreement is attached to the income tax DEPARTMENT OF THE TREASURY Estimated Number of Responses: 100.
return of the dual resident corporation Estimated Time Per Response: 10
or group, to take the loss into income Internal Revenue Service hours.
upon future use of the loss in the foreign Estimated Total Annual Burden
country. The regulation also requires Proposed Collection; Comment Hours: 1,000.
separate accounting for a dual Request for Regulation Project The following paragraph applies to all
consolidated loss where the dual of the collections of information covered
AGENCY: Internal Revenue Service (IRS),
resident corporation files a consolidated by this notice:
Treasury.
return. An agency may not conduct or
ACTION: Notice and request for sponsor, and a person is not required to
Current Actions: There is no change to
comments. respond to, a collection of information
this existing regulation.
Type of Review: Extension of a SUMMARY: The Department of the unless the collection of information
currently approved collection. Treasury, as part of its continuing effort displays a valid OMB control number.
Affected Public: Business or other for- to reduce paperwork and respondent Books or records relating to a
profit organizations. burden, invites the general public and collection of information must be
Estimated Number of Respondents: other Federal agencies to take this retained as long as their contents may
500. opportunity to comment on proposed become material in the administration
Estimated Number of Responses: 896. and/or continuing information of any internal revenue law. Generally,
Estimated Time per Response: 1 hr., collections, as required by the tax returns and tax return information
49 minutes. Paperwork Reduction Act of 1995. are confidential, as required by 26
Estimated Total Annual Burden Currently, the IRS is soliciting U.S.C. 6103.
Hours: 1,620. comments concerning certain transfers Request for Comments: Comments
The following paragraph applies to all of domestic stock or securities by U.S. submitted in response to this notice will
of the collections of information covered persons to foreign corporations. be summarized and/or included in the
by this notice: request for OMB approval. All
DATES: Written comments should be
An agency may not conduct or comments will become a matter of
sponsor, and a person is not required to received on or before May 23, 2017 to public record. Comments are invited on:
respond to, a collection of information be assured of consideration. (a) Whether the collection of
unless the collection of information ADDRESSES: Direct all written comments information is necessary for the proper
displays a valid OMB control number. to Laurie Brimmer, Internal Revenue performance of the functions of the
jstallworth on DSK7TPTVN1PROD with NOTICES

Books or records relating to a collection Service, Room 6526, 1111 Constitution agency, including whether the
of information must be retained as long Avenue NW., Washington, DC 20224. information shall have practical utility;
as their contents may become material FOR FURTHER INFORMATION CONTACT: (b) the accuracy of the agency’s estimate
in the administration of any internal Requests for additional information or of the burden of the collection of
revenue law. Generally, tax returns and copies of the regulations should be information; (c) ways to enhance the
tax return information are confidential, directed to Kerry Dennis at Internal quality, utility, and clarity of the
as required by 26 U.S.C. 6103. Revenue Service, Room 6526, 1111 information to be collected; (d) ways to

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Document Created: 2018-02-01 15:10:51
Document Modified: 2018-02-01 15:10:51

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		Notices
Action		Notice and request for comments.
Dates		Written comments should be received on or before May 23, 2017 to be assured of consideration.
Contact		Requests for additional information or copies of the regulations should be directed to Kerry Dennis at Internal Revenue Service, 1111 Constitution Avenue NW., Room 6526, Washington, DC 20224, or through the internet at [email protected]
FR Citation		82 FR 15102

82 FR 15102 - Proposed Collection; Comment Request for Regulation Project

DEPARTMENT OF THE TREASURYInternal Revenue Service

Federal Register Volume 82, Issue 56 (March 24, 2017)

DEPARTMENT OF THE TREASURY
Internal Revenue Service