Document
Agency Information Collection Activities; Comment Request for Conduit Arrangements Recordkeeping Requirements
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this oppo...
SUPPLEMENTARY INFORMATION:
Title:
Conduit Arrangements Recordkeeping Requirements.
OMB Number:
1545-1440.
Regulation Number:
T.D. 8611.
Abstract:
Treasury Decision (TD) 8611 provides rules that permit the district director to recharacterize a financing arrangement as a conduit arrangement. The recharacterization will affect the amount of U.S. withholding tax due on financing transactions that are part of the financing arrangement. This TD requires parties to the financing arrangement maintain specific records about the transaction and its circumstances, as detailed in 26 CFR 1.881-4(c). Additionally, each Section 6038 or 6038A party to the financing arrangement must comply with the recordkeeping requirements of 26 CFR 1.6038A-3 with respect to records that are relevant to the determination under § 1.881-3 of the regulations.
Current Actions:
There is no change in the paperwork burden previously approved by OMB.
Type of Review:
Extension of a currently approved collection.
Affected Public:
Business or other for-profit organizations.
Estimated Number of Respondents:
1,000.
Estimated Time per Respondent:
10 minutes.
Estimated Total Annual Burden Hours:
10,000 hours.
The following paragraph applies to all 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 if 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: May 6, 2025.
Molly J. Stasko,
Senior Tax Analyst.