82 FR 52848 - Treatment of Certain Transfers of Property to Foreign Corporations; Correction
DEPARTMENT OF THE TREASURY
Internal Revenue Service Federal Register Volume 82, Issue 219 (November 15, 2017)
Internal Revenue Service
Federal Register Volume 82, Issue 219 (November 15, 2017)
| Page Range | 52848-52848 | |
| FR Document | 2017-24687 |
[Federal Register Volume 82, Number 219 (Wednesday, November 15, 2017)] [Rules and Regulations] [Page 52848] From the Federal Register Online [www.thefederalregister.org] [FR Doc No: 2017-24687] ======================================================================= ----------------------------------------------------------------------- DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9803] RIN 1545-BL87 Treatment of Certain Transfers of Property to Foreign Corporations; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. ----------------------------------------------------------------------- SUMMARY: This document contains corrections to final regulations (TD 9803) that were published in the Federal Register on Friday, December 16, 2016. The final regulations are related to certain transfers of property by United States persons to foreign corporations. DATES: This correction is effective on November 15, 2017 and is applicable on or after December 16, 2016. FOR FURTHER INFORMATION CONTACT: Lynlee Baker at (202) 317-6937 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations (TD 9803) that are the subject of this correction are issued under section 367 of the Internal Revenue Code. Need for Correction As published, the final regulations published in the Federal Register on Friday, December 16, 2016 (81 FR 91012) (TD 9803) contain an error that needs to be corrected. Specifically, paragraph (e) was inadvertently omitted from the final regulations. 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 amendment: 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 1.367(a)-1 is amended by adding paragraph (e) to read as follows: Sec. 1.367(a)-1 Transfers to foreign corporations subject to section 367(a): In general. * * * * * (e) Close of taxable year in certain section 368(a)(1)(F) reorganizations. If a domestic corporation is the transferor corporation in a reorganization described in section 368(a)(1)(F) after March 30, 1987, in which the acquiring corporation is a foreign corporation, then the taxable year of the transferor corporation shall end with the close of the date of the transfer and the taxable year of the acquiring corporation shall end with the close of the date on which the transferor's taxable year would have ended but for the occurrence of the transfer. With regard to the consequences of the closing of the taxable year, see section 381 and the regulations thereunder. * * * * * Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. 2017-24687 Filed 11-14-17; 8:45 am] BILLING CODE 4830-01-P
![52848 Federal Register / Vol. 82, No. 219 / Wednesday, November 15, 2017 / Rules and Regulations
standards and practices to determine if PART 1—INCOME TAXES FOR FURTHER INFORMATION CONTACT:
it should take action in the future. Daniel S. Liebman (liebman.daniel@
By direction of the Commission.
■ Paragraph 1. The authority citation pbgc.gov), Acting Assistant General
for part 1 continues to read in part as Counsel for Regulatory Affairs, Pension
Donald S. Clark,
follows: Benefit Guaranty Corporation, 1200 K
Secretary.
Authority: 26 U.S.C. 7805 * * * Street NW., Washington, DC 20005,
[FR Doc. 2017–24728 Filed 11–14–17; 8:45 am]
■ Par. 2. Section 1.367(a)–1 is amended 202–326–4400 ext. 6510. (TTY/TDD
BILLING CODE 6750–01–P users may call the Federal relay service
by adding paragraph (e) to read as
follows: toll-free at 1–800–877–8339 and ask to
be connected to 202–326–4400, ext.
§ 1.367(a)–1 Transfers to foreign 6510.)
DEPARTMENT OF THE TREASURY corporations subject to section 367(a): In
general. SUPPLEMENTARY INFORMATION: PBGC’s
Internal Revenue Service regulation on Benefits Payable in
* * * * * Terminated Single-Employer Plans (29
26 CFR Part 1 (e) Close of taxable year in certain CFR part 4022) prescribes actuarial
section 368(a)(1)(F) reorganizations. If a assumptions—including interest
domestic corporation is the transferor assumptions—for paying plan benefits
[TD 9803] corporation in a reorganization under terminated single-employer plans
described in section 368(a)(1)(F) after covered by title IV of the Employee
RIN 1545–BL87 March 30, 1987, in which the acquiring Retirement Income Security Act of 1974.
corporation is a foreign corporation, The interest assumptions in the
Treatment of Certain Transfers of then the taxable year of the transferor
Property to Foreign Corporations; regulation are also published on PBGC’s
corporation shall end with the close of Web site (http://www.pbgc.gov).
Correction the date of the transfer and the taxable PBGC uses the interest assumptions in
AGENCY: Internal Revenue Service (IRS), year of the acquiring corporation shall appendix B to part 4022 to determine
Treasury. end with the close of the date on which whether a benefit is payable as a lump
the transferor’s taxable year would have sum and to determine the amount to
ACTION: Correcting amendment.
ended but for the occurrence of the pay. Appendix C to part 4022 contains
SUMMARY: This document contains transfer. With regard to the interest assumptions for private-sector
corrections to final regulations (TD consequences of the closing of the pension practitioners to refer to if they
9803) that were published in the taxable year, see section 381 and the wish to use lump-sum interest rates
Federal Register on Friday, December regulations thereunder. determined using PBGC’s historical
16, 2016. The final regulations are * * * * * methodology. Currently, the rates in
related to certain transfers of property Martin V. Franks, appendices B and C of the benefit
by United States persons to foreign Chief, Publications and Regulations Branch,
payment regulation are the same.
corporations. Legal Processing Division, Associate Chief The interest assumptions are intended
DATES: This correction is effective on Counsel (Procedure and Administration). to reflect current conditions in the
November 15, 2017 and is applicable on [FR Doc. 2017–24687 Filed 11–14–17; 8:45 am] financial and annuity markets.
or after December 16, 2016. BILLING CODE 4830–01–P
Assumptions under the benefit
payments regulation are updated
FOR FURTHER INFORMATION CONTACT: monthly. This final rule updates the
Lynlee Baker at (202) 317–6937 (not a benefit payments interest assumptions
toll-free number). for December 2017.1
PENSION BENEFIT GUARANTY
SUPPLEMENTARY INFORMATION: CORPORATION The December 2017 interest
assumptions under the benefit payments
Background
29 CFR Part 4022 regulation will be 0.75 percent for the
The final regulations (TD 9803) that period during which a benefit is in pay
are the subject of this correction are Benefits Payable in Terminated Single- status and 4.00 percent during any years
issued under section 367 of the Internal Employer Plans; Interest Assumptions preceding the benefit’s placement in pay
Revenue Code. for Paying Benefits status. In comparison with the interest
Need for Correction assumptions in effect for November
AGENCY: Pension Benefit Guaranty
2017, these assumptions are unchanged.
As published, the final regulations Corporation.
PBGC has determined that notice and
published in the Federal Register on ACTION: Final rule. public comment on this amendment are
Friday, December 16, 2016 (81 FR impracticable and contrary to the public
SUMMARY: This final rule amends the
91012) (TD 9803) contain an error that interest. This finding is based on the
Pension Benefit Guaranty Corporation’s
needs to be corrected. Specifically, need to determine and issue new
regulation on Benefits Payable in
paragraph (e) was inadvertently omitted interest assumptions promptly so that
Terminated Single-Employer Plans to
from the final regulations. the assumptions can reflect current
prescribe interest assumptions under
List of Subjects in 26 CFR Part 1 the regulation for valuation dates in market conditions as accurately as
possible.
sradovich on DSK3GMQ082PROD with RULES
Income taxes, Reporting and December 2017. The interest
recordkeeping requirements. assumptions are used for paying 1 Appendix B to PBGC’s regulation on Allocation
benefits under terminating single- of Assets in Single-Employer Plans (29 CFR part
Correction of Publication employer plans covered by the pension 4044) prescribes interest assumptions for valuing
Accordingly, 26 CFR part 1 is insurance system administered by benefits under terminating covered single-employer
PBGC. plans for purposes of allocation of assets under
corrected by making the following ERISA section 4044. Those assumptions are
correcting amendment: DATES: Effective December 1, 2017. updated quarterly.
VerDate Sep<11>2014 15:48 Nov 14, 2017 Jkt 244001 PO 00000 Frm 00026 Fmt 4700 Sfmt 4700 E:\FR\FM\15NOR1.SGM 15NOR1](https://thefederalregister.org/doc/82_FR_53067/page/1.svg)
Document Created: 2018-10-25 10:37:47
Document Modified: 2018-10-25 10:37:47
| 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 | Rules and Regulations | |
| Action | Correcting amendment. | |
| Dates | This correction is effective on November 15, 2017 and is applicable on or after December 16, 2016. | |
| Contact | Lynlee Baker at (202) 317-6937 (not a toll-free number). | |
| FR Citation | 82 FR 52848 | |
| RIN Number | 1545-BL87 | |
| CFR Associated | Income Taxes and Reporting and Recordkeeping Requirements |
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