Department of Defense Education Activity (DoDEA), 72917 [05-23768]
Download as PDF
<![CDATA[
Federal Register / Vol. 70, No. 235 / Thursday, December 8, 2005 / Rules and Regulations
paying the tax and interest due on the
excess distribution. A shareholder that
makes the deemed dividend election
after the due date of the return
(determined without regard to
extensions) for the election year must
pay additional interest, pursuant to
section 6601, on the amount of
underpayment of tax for that year.
(ii) Attachment to Form 8621. The
shareholder must attach a schedule to
Form 8621 that demonstrates the
calculation of the shareholder’s pro rata
share of the post-1986 earnings and
profits of the PFIC that is treated as
distributed to the shareholder on the
termination date pursuant to this
paragraph (c). If the shareholder is
claiming an exclusion from its pro rata
share of the post-1986 earnings and
profits for an amount previously
included in its income or the income of
another U.S. person, the shareholder
must include the following information:
(A) The name, address, and taxpayer
identification number of each U.S.
person that previously included an
amount in income, the amount
previously included in income by each
such U.S. person, the provision of law
pursuant to which the amount was
previously included in income, and the
taxable year or years of inclusion of
each amount.
(B) A description of the transaction
pursuant to which the shareholder
acquired, directly or indirectly, the
stock of the PFIC from another U.S.
person, and the provision of law
pursuant to which the shareholder’s
holding period includes the period the
other U.S. person held the CFC stock.
(6) Adjustments to basis. A
shareholder that makes the deemed
dividend election increases its adjusted
basis of the stock of the PFIC owned
directly by the shareholder by the
amount of the deemed dividend. If the
shareholder makes the deemed dividend
election with respect to a PFIC of which
it is an indirect shareholder, the
shareholder’s adjusted basis of the stock
or other property owned directly by the
shareholder, through which ownership
of the PFIC is attributed to the
shareholder, is increased by the amount
of the deemed dividend. In addition,
solely for purposes of determining the
subsequent treatment under the Code
and regulations of a shareholder of the
stock of the PFIC, the adjusted basis of
the direct owner of the stock of the PFIC
is increased by the amount of the
deemed dividend.
(7) Treatment of holding period. If the
shareholder of a foreign corporation has
made a deemed dividend election, then,
for purposes of applying sections 1291
through 1298 to such shareholder after
VerDate Aug<31>2005
15:29 Dec 07, 2005
Jkt 208001
the deemed dividend, the shareholder’s
holding period of the stock of the
foreign corporation begins on the day
following the termination date. For
other purposes of the Code and
regulations, this holding period rule
does not apply.
(8) Coordination with section 959(e).
For purposes of section 959(e), the
entire deemed dividend is treated as
having been included in gross income
under section 1248(a).
(d) Termination date. For purposes of
this section, the termination date is the
last day of the last taxable year of the
foreign corporation during which it
qualified as a PFIC under section
1297(a).
(e) Late purging elections requiring
special consent. [Reserved]. For further
guidance, see § 1.1298–3T(e).
(f) Effective date. This section applies
for taxable years of shareholders
beginning on or after December 8, 2005.
However, taxpayers may apply the rules
of this section to a taxable year
beginning prior to December 8, 2005,
provided the statute of limitations on
the assessment of tax has not expired.
PART 602—OMB CONTROL NUMBERS
UNDER THE PAPERWORK
REDUCTION ACT
Par. 6. The authority citation for part
602 continues to read as follows:
I
Authority: 26 U.S.C. 7805.
Par. 7. In § 602.101, paragraph (b) is
amended by adding an entry in
numerical order to the table as follows:
I
§ 602.101
*
*
*
*
*
*
1.1298–3 ...............................
*
*
Current OMB
control No.
*
*
1545–1507
*
*
Approved: November 21, 2005.
Mark E. Matthews,
Deputy Commissioner for Services and
Enforcement.
Eric Solomon,
Acting Deputy Assistant Secretary of the
Treasury.
[FR Doc. 05–23629 Filed 12–7–05; 8:45 am]
BILLING CODE 4830–01–P
PO 00000
Frm 00037
Office of the Secretary
32 CFR Part 346
Department of Defense Education
Activity (DoDEA)
Department of Defense.
Final rule.
AGENCY:
ACTION:
SUMMARY: This document removes 32
CFR Part 346, ‘‘DoD Education
Activity’’. This part has served the
purpose for which it was intended and
is no longer needed. A copy of DoD
Directive 1342.20, ‘‘Department of
Defense Education Activity (DoDEA),’’
is available at https://www.dtic.mil/whs/
directives/.
EFFECTIVE DATE: This rule is effective
November 28, 2005.
FOR FURTHER INFORMATION CONTACT: L.M.
Bynum 703–696–4970.
List of Subjects in 32 CFR Part 346
Education, Military personnel,
Organization and functions
(Government agencies).
PART 346—[REMOVED]
For reasons set forth in the preamble,
under the authority of 10 U.S.C. 131, 32
CFR Part 346 is removed.
I
Dated: December 2, 2005.
L.M. Bynum,
Alternate OSD Federal Register Liaison,
Department of Defense.
[FR Doc. 05–23768 Filed 12–7–05; 8:45 am]
BILLING CODE 5001–06–M
40 CFR Part 86
CFR part or section where
identified and described
*
DEPARTMENT OF DEFENSE
ENVIRONMENTAL PROTECTION
AGENCY
OMB Control numbers.
*
*
(b) * * *
72917
Fmt 4700
Sfmt 4700
[OAR–2004–0011; FRL 8004–7]
RIN 2060–AM32
Control of Air Pollution From New
Motor Vehicles and New Motor Vehicle
Engines: Technical Amendments to
Evaporative Emissions Regulations,
Dynamometer Regulations, and
Vehicle Labeling
Environmental Protection
Agency (EPA).
ACTION: Direct final rule.
AGENCY:
SUMMARY: EPA is taking direct final
action to make changes to certain
provisions of the evaporative and
refueling emission regulations for lightduty vehicles, light-duty trucks and
heavy-duty vehicles up to 14,000
E:\FR\FM\08DER1.SGM
08DER1
]]>Agencies
[Federal Register Volume 70, Number 235 (Thursday, December 8, 2005)]
[Rules and Regulations]
[Page 72917]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 05-23768]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF DEFENSE
Office of the Secretary
32 CFR Part 346
Department of Defense Education Activity (DoDEA)
AGENCY: Department of Defense.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: This document removes 32 CFR Part 346, ``DoD Education
Activity''. This part has served the purpose for which it was intended
and is no longer needed. A copy of DoD Directive 1342.20, ``Department
of Defense Education Activity (DoDEA),'' is available at https://
www.dtic.mil/whs/directives/.
EFFECTIVE DATE: This rule is effective November 28, 2005.
FOR FURTHER INFORMATION CONTACT: L.M. Bynum 703-696-4970.
List of Subjects in 32 CFR Part 346
Education, Military personnel, Organization and functions
(Government agencies).
PART 346--[REMOVED]
0
For reasons set forth in the preamble, under the authority of 10 U.S.C.
131, 32 CFR Part 346 is removed.
Dated: December 2, 2005.
L.M. Bynum,
Alternate OSD Federal Register Liaison, Department of Defense.
[FR Doc. 05-23768 Filed 12-7-05; 8:45 am]
BILLING CODE 5001-06-M
