REMIC Residual Interests-Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders), 43363-43366 [E6-12363]

Agencies

• Internal Revenue Service
• DEPARTMENT OF THE TREASURY

[Federal Register Volume 71, Number 147 (Tuesday, August 1, 2006)]
[Rules and Regulations]
[Pages 43363-43366]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-12363]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9272]
RIN 1545-BE81


REMIC Residual Interests--Accounting for REMIC Net Income 
(Including Any Excess Inclusions) (Foreign Holders)

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations.

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SUMMARY: This document contains temporary regulations relating to 
income that is associated with a residual interest in a Real Estate 
Mortgage Investment Conduit (REMIC) and that is allocated through 
certain entities to foreign persons who have invested in those 
entities. The regulations accelerate the time when income is recognized 
for withholding tax purposes to conform to the timing of income 
recognition for general income tax purposes. The foreign persons 
covered by these regulations include partners in domestic partnerships, 
shareholders of real estate investment trusts, shareholders of 
regulated investment companies, participants in common trust funds, and 
patrons of subchapter T cooperatives. These regulations are necessary 
to prevent inappropriate avoidance of current income tax liability by 
foreign persons to whom income from REMIC residual interests is 
allocated. The regulations clarify the timing of income under section 
860G for purposes of determining a domestic partnership's 
responsibility under sections 1441 and 1442 for withholding tax with 
respect to a foreign partner's share of REMIC net income as a result of 
indirectly holding a residual interest. The regulations also provide 
that an excess inclusion is treated as income from sources within the 
United States. The text of the temporary regulations also serves as the 
text of the proposed regulations set forth in the notice of proposed 
rulemaking on this subject in the Proposed Rules section in this issue 
of the Federal Register.

DATES: Effective Date: These regulations are effective August 1, 2006.
    Applicability Dates: For dates of applicability, see Sec. Sec.  
1.860A-1T(b)(5), 1.863-1T(f) and 1.1441-2T(f).

FOR FURTHER INFORMATION CONTACT: Dale Collinson, (202) 622-3900 (not a 
toll-free number).

Background and Explanation of Provisions

    This document contains amendments to 26 CFR part 1 under sections 
860A, 860G(b), 863, 1441, and 1442 of the Internal Revenue Code (Code). 
Under section 860C(a)(1), in general, a holder of a REMIC residual 
interest must take into account the holder's daily portion of the 
taxable income or net loss of the REMIC for each day of the taxable 
year on which the holder held the interest. Thus, a residual interest 
holder generally is taxable currently on the taxable income or net loss 
of the REMIC without regard to whether or when the REMIC makes 
distributions. Section 860G(b) provides an exception to this general 
rule in section 860C for the timing of income attributable to the 
ownership of a REMIC residual interest. Under this exception, for 
purposes of sections 871(a), 881, 1441, and 1442, if amounts are 
includible in the income of a holder of a REMIC residual interest that 
is a nonresident alien individual or a foreign corporation, the amounts 
are taken into account only when paid or distributed to the foreign 
holder, or when the interest is disposed of.
    In its earlier years, a REMIC may accrue and recognize more taxable 
interest income from the mortgages that it holds than it accrues and 
deducts as interest on the regular interests that it has issued. This 
produces net income for the REMIC and thus for the holder of the 
REMIC's residual interest. Many REMICs are structured so that the REMIC 
uses all, or substantially all, of its cash flow to pay expenses and to 
pay principal and interest on regular interests (effectively using a 
portion of interest receipts to pay principal or other nondeductible 
items). Such a REMIC will make little or no distributions to the 
holders of the residual interest in the REMIC, and each holder will 
incur tax liabilities with respect to its share of the REMIC's net 
income in an amount that exceeds the holder's economic return.
    In addition, all or substantially all of the income attributable to 
holding the residual interest will be subject to special rules relating 
to excess inclusions. To ensure that the income will be taxable in all 
events, these rules, among other things, prevent the use of net 
operating losses to offset the excess inclusions, see section 860E, and 
preclude any exemption from, or reduction in, applicable withholding 
taxes, see section 860G(b)(2). Residual interests that entitle the 
holder to little or no distributions are commonly referred to as 
noneconomic REMIC residual interests, and persons acquiring those 
interests receive an inducement fee for becoming the holder and 
undertaking the associated tax payment responsibilities. Taxable income 
that must be recognized in excess of the economic income for a period 
is often called phantom income. In the case of a REMIC, the early 
phantom income is generally offset by matching deductions (generally 
called phantom losses) in later periods.
    Consistent with the Congressional purpose of ensuring that excess 
inclusions of REMICs be subject to tax, Sec.  1.860E-1(c) of the Income 
Tax Regulations provides for disregarding transfers of noneconomic 
REMIC residual interests if a significant purpose of the transfer is 
avoiding assessment or collection of tax. In addition, Sec.  1.860G-
3(a)(1) provides, ``A transfer of a residual interest that has tax 
avoidance potential is disregarded for all Federal income tax purposes 
if the transferee is a foreign person.'' Section 1.860G-3(a)(2) 
provides, ``A residual interest has tax avoidance potential * * * 
unless, at the time of the transfer, the transferor reasonably expects 
that, for each excess inclusion, the REMIC will distribute to the 
transferee residual interest holder an amount that will equal at least 
30 percent of the excess inclusion, and that each such amount will be 
distributed at or after the time at which the excess inclusion accrues 
and not later than the close of the calendar year following the 
calendar year of accrual.'' Accordingly, foreign persons are generally 
precluded from becoming the direct holders of noneconomic residual 
interests.
    ``Where necessary or appropriate to prevent the avoidance of tax 
imposed by [chapter 1 of the Code],'' section 860G(b) authorizes the 
adoption of regulations requiring REMIC net income inclusions of 
foreign holders of REMIC residual interests to be taken into account 
for purposes of sections 871(a), 881, 1441, and 1442 earlier than is 
provided in section 860G(b)(1). The legislative history of the Tax 
Reform Act of 1986 indicates that Congress intended that this 
regulatory authority may be exercised with respect to noneconomic 
residual interests. See 2 H.R. Rep. No. 841, 99th Cong., 2d Sess. II-
236 (1986) (referring to residual interests that do ``not have 
significant value'').
    The IRS and Treasury Department have become aware that noneconomic 
REMIC residual interests are being

[[Page 43364]]

transferred to domestic partnerships that subsequently allocate the 
phantom income to foreign persons. If a partnership has no foreign 
partners at the time the partnership acquires a noneconomic REMIC 
residual interest, the person transferring the residual interest to the 
partnership may take the position that neither Sec.  1.860E-1(c) nor 
Sec.  1.860G-3 is applicable. In turn, the partnership may take the 
position, by applying the aggregate approach to the relation between a 
partnership and its partners, that foreign persons who later become 
partners hold the REMIC residual interest that had previously been 
acquired by the partnership. Based on the conclusion that the foreign 
partners are holders of the residual interest, the partnership may take 
the further position that, under section 860G(b), a withholding tax 
obligation on the partnership's allocation to the foreign partner of 
income from the residual interest arises no sooner than the time when 
distributions on the residual interest are made by the REMIC 
(distributions that will almost never occur with a noneconomic 
residual) or when the interest is disposed of. Under this view, the 
foreign holder's tax liability with respect to net income of the REMIC 
(including excess inclusions) would be deferred until disposition of 
the holder's interest in the REMIC residual interest, including a 
disposition through termination of the REMIC, a disposition of the 
REMIC residual interest by the partnership, or a disposition of the 
partnership interest by the foreign partner.
    The IRS and Treasury Department have concluded that, in order to 
achieve effective assessment and collection of U.S. tax on REMIC net 
income, including excess inclusion income, in furtherance of the 
congressional purpose referenced above and section 860E(a)(1), (b), and 
(e) and section 860G(b) of the Code, the time when foreign partners are 
required to account for REMIC net income should be accelerated. That 
is, for purposes of sections 871(a), 881, 1441, and 1442, the temporary 
regulations eliminate the deferral (relative to section 860C) that 
section 860G(b)(1) might otherwise prescribe. To prevent the adoption 
of similar schemes using real estate investment trusts, regulated 
investment companies, common trust funds, or subchapter T cooperative 
organizations, foreign persons to whom excess inclusion income is 
allocated by any of these other entities must account for REMIC excess 
inclusions on a similarly accelerated basis.
    Several provisions of regulations under sections 1441 and 1442 are 
relevant to the taxation of REMIC net income inclusions (and 
particularly net income inclusions with respect to noneconomic REMIC 
residual interests) that are allocated to foreign persons. Under Sec.  
1.1441-2(e), for purposes of section 1441 and 1442, a payment generally 
is considered made to a person if that person realizes income, whether 
or not the income results from an actual transfer of cash or other 
property. Under Sec.  1.1441-2(d)(1), however, if a withholding agent 
is not related to the recipient or beneficial owner, the withholding 
agent has an obligation to withhold only to the extent that, at any 
time between the date that the obligation to withhold would arise but 
for the provisions of Sec.  1.1441-2(d) and the due date for the filing 
of a return on Form 1042, ``Annual Withholding Tax Return for U.S. 
Source Income of Foreign Persons,'' (including extensions) for the year 
in which the payment occurs, the withholding agent has control over, or 
custody of money or property owned by the recipient or beneficial owner 
from which to withhold an amount and has knowledge of the facts that 
give rise to the payment. For this purpose, a withholding agent is 
related to the recipient or beneficial owner if it is related within 
the meaning of section 482. Section 1.1441-2(d)(1) further provides 
that the foregoing exception does not apply ``to distributions with 
respect to stock or if the lack of control or custody of money or 
property owned by the recipient or beneficial owner from which to 
withhold is part of a prearranged plan known to the withholding agent 
to avoid withholding under sections 1441, 1442, or 1443.''
    Under Sec.  1.1441-5(b)(2), a U.S. partnership is required to 
withhold under Sec.  1.1441-1 as a withholding agent on an amount 
subject to withholding (as defined in Sec.  1.1441-2(a)) that is 
includible in the gross income of a partner that is a foreign person. 
Except as provided in Sec.  1.1441-5(b)(2)(v) (which prevents a second 
withholding obligation from arising with respect to the actual 
distribution of income previously withheld upon as a distribution from 
a U.S. partnership or trust), a U.S. partnership is required to 
withhold when making any distributions that include amounts subject to 
withholding. To the extent a foreign partner's distributive share of 
income subject to withholding has not actually been distributed to the 
foreign partner, the U.S. partnership must withhold on the foreign 
partner's distributive share of the income on the earlier of the date 
that the statement on Form 1065, ``U.S. Return of Partnership Income,'' 
is mailed (or otherwise provided) to the partner or the due date for 
furnishing that statement.
    Pursuant to the authority granted under section 860G(b), for 
purposes of sections 871(a), 881, 1441, and 1442, these temporary 
regulations generally require a foreign partner in a partnership 
holding one or more REMIC residual interests to take into account REMIC 
net income inclusions at the end of its taxable year (or on the last 
date of the taxable year of a partnership that allocates REMIC net 
income to the foreign partner). The temporary regulations require a 
foreign shareholder in a real estate investment trust or regulated 
investment company, a foreign participant in a common trust fund, or a 
foreign patron of a subchapter T cooperative organization to take into 
account excess inclusion income at the same time as other income from 
the entity.
    The temporary regulations also provide that an excess inclusion is 
treated as income from sources within the United States. The Treasury 
Department and the IRS believe this treatment is appropriate because 
the inclusions are largely phantom income arising from the special 
provisions of the Code relating to REMICs and thus are unlikely to have 
tax significance outside the United States. The temporary regulations 
provide that, to the extent excess inclusions are taken into account 
with respect to a residual interest, net losses with respect to the 
residual interest are allocated and apportioned to the class and 
grouping(s) of gross income to which the excess inclusions were 
assigned.
    The temporary regulations also provide that the exemption available 
under certain circumstances to certain withholding agents that do not 
have custody or control of money or property from which to satisfy a 
withholding obligation is not available in any case with respect to an 
excess inclusion subject to these rules. No inference is intended as to 
whether, for purposes of this exemption, any right, obligation, 
contract, or arrangement other than a REMIC residual interest 
constitutes property of a sort from which a withholding obligation may 
be satisfied.

Effective Date

    The regulations regarding the timing of REMIC income inclusions 
apply to REMIC net income of a foreign person with respect to REMIC 
residual interests with respect to which the first REMIC net income 
allocation to the foreign person under section 860C occurs on or after 
August 1, 2006. The regulations

[[Page 43365]]

regarding the source of excess inclusions are applicable for taxable 
years ending after August 1, 2006.

Special Analyses

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in Executive Order 12866. 
Therefore, a regulatory assessment is not required. These regulations 
are necessary to provide taxpayers with immediate guidance to 
discourage the overly aggressive interpretations being employed for the 
inappropriate avoidance of current income tax assessment or collection 
by foreign persons who are allocated income from REMIC residual 
interests. Accordingly, good cause is found for dispensing with notice 
and public comment pursuant to 5 U.S.C. 553(b)(B), and with a delayed 
effective date pursuant to 5 U.S.C. 553(d). For the applicability of 
the Regulatory Flexibility Act (5 U.S.C. chapter 6) refer to the 
special analysis section of the preamble to the cross-referenced notice 
of proposed rulemaking published in the Proposed Rules section in this 
issue of the Federal Register. Pursuant to section 7805(f) of Code, 
these temporary regulations will be submitted to the Chief Counsel for 
Advocacy of the Small Business Administration for comment on its impact 
on small business.

Drafting Information

    The principal author of these regulations is Dale Collinson, Office 
of the Associate Chief Counsel (Financial Institutions and Products). 
However, other personnel from the IRS and Treasury Department 
participated in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations

0
Accordingly, 26 CFR part 1 is amended as follows:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 is amended by adding 
entries in numerical order to read, in part, as follows:

    Authority: 26 U.S.C. 7805 * * *
    Section 1.860A-1 also issued under 26 U.S.C. 860G(b) and 
860G(e).
    Section 1.860A-1T also issued under 26 U.S.C. 860G(b) and 
860G(e). * * *
    Section 1.860G-3T also issued under 26 U.S.C. 860G(b) and 
860G(e). * * *


0
Par. 2. Section 1.860A-0 is amended as follows:
0
1. Section 1.860A-1, paragraph (b)(5) is added.
0
2. Section 1.860A-1T is added.
0
3. Section 1.860G-3, paragraph (b) is revised.
0
4. Section 1.860G-3T is added.
    The additions and revisions read as follows:


Sec.  1.860A-0  Outline of REMIC provisions.

* * * * *


Sec.  1.860A-1  Effective dates and transition rules.

* * * * *
    (b) * * *
    (5) [Reserved].


Sec.  1.860A-1T  Effective dates and transition rules (temporary).

    (a) through (b)(4) [Reserved].
    (5) Accounting for REMIC net income of foreign persons.
* * * * *


Sec.  1.860G-3  Treatment of foreign persons.

* * * * *
    (b) Accounting for REMIC net income. [Reserved].


Sec.  1.860G-3T  Treatment of foreign persons (temporary).

    (a) [Reserved].
    (b) Accounting for REMIC net income.
    (1) Allocation of partnership income to a foreign partner.
    (2) Excess inclusion income allocated by certain pass-through 
entities to a foreign person.

0
Par. 3. In Sec.  1.860A-1 paragraph (b)(5) is added to read as follows:


Sec.  1.860A-1  Effective dates and transition rules.

* * * * *
    (b) * * *
    (5) [Reserved]. For further guidance, see Sec.  1.860A-1T(b)(5).

0
Par. 4. Section 1.860A-1T is added to read as follows:


Sec.  1.860A-1T  Effective dates and transition rules (temporary).

    (a) through (b)(4) [Reserved]. For further guidance, see Sec.  
1.860A-1(a) through (b)(4).
    (5) Accounting for REMIC net income of foreign persons. Section 
1.860G-3T(b) is applicable to REMIC net income (including excess 
inclusions) of a foreign person with respect to a REMIC residual 
interest if the first net income allocation under section 860C(a)(1) to 
the foreign person with respect to that interest occurs on or after 
August 1, 2006. This section will expire July 31, 2009.

0
Par. 5. In Sec.  1.860G-3, paragraph (b) is revised as follows:


Sec.  1.860G-3  Treatment of foreign persons.

* * * * *
    (b) Accounting for REMIC net income. [Reserved]. For further 
guidance, see Sec.  1.860G-3T(b).

0
Par. 6. Section 1.860G-3T is added to read as follows:


Sec.  1.860G-3T  Treatment of foreign persons (temporary).

    (a) [Reserved]. For further guidance, see Sec.  1.860G-3(a).
    (b) Accounting for REMIC net income--(1) Allocation of partnership 
income to a foreign partner. A domestic partnership shall separately 
state its allocable share of REMIC taxable income or net loss in 
accordance with Sec.  1.702-1(a)(8). If a domestic partnership 
allocates all or some portion of its allocable share of REMIC taxable 
income to a partner that is a foreign person, the amount allocated to 
the foreign partner shall be taken into account by the foreign partner 
for purposes of sections 871(a), 881, 1441, and 1442 as if that amount 
were received on the last day of the partnership's taxable year, except 
to the extent that some or all of the amount is required to be taken 
into account by the foreign partner at an earlier time under section 
860G(b) as a result of a distribution by the partnership to the foreign 
partner or a disposition of the foreign partner's indirect interest in 
the REMIC residual interest. A disposition in whole or in part of the 
foreign partner's indirect interest in the REMIC residual interest may 
occur as a result of a termination of the REMIC, a disposition of the 
partnership's residual interest in the REMIC, a disposition of the 
foreign partner's interest in the partnership, or any other reduction 
in the foreign partner's allocable share of the portion of the REMIC 
net income or deduction allocated to the partnership. See Sec.  1.871-
14(d)(2) for the treatment of interest received on a regular or 
residual interest in a REMIC. For a partnership's withholding 
obligations with respect to excess inclusion amounts described in this 
paragraph (b)(1), see Sec.  1.1441-2T(b)(5), Sec.  1.1441-2T(d)(4), 
Sec.  1.1441-5(b)(2)(i)(A) and Sec. Sec.  1.1446-1 through 1.1446-7.
    (2) Excess inclusion income allocated by certain pass-through 
entities to a foreign person. If an amount is allocated under section 
860E(d)(1) to a foreign person that is a shareholder of a real estate 
investment trust or a regulated investment company, a participant in a 
common trust fund, or a patron of an organization to which part I of 
subchapter T applies and if the amount so allocated is governed by 
section 860E(d)(2) (treating it ``as an excess

[[Page 43366]]

inclusion with respect to a residual interest held by'' the taxpayer), 
the amount shall be taken into account for purposes of sections 871(a), 
881, 1441, and 1442 at the same time as the time prescribed for other 
income of the shareholder, participant, or patron from the trust, 
company, fund, or organization.

0
Par. 7. Section 1.863-0 table of contents is amended as follows:
0
1. The entries for Sec.  1.863-1(e) are revised.
0
2. Entries for Sec.  1.863-1T are added.
    The revisions and additions read as follows:


Sec.  1.863-0  Table of contents.

* * * * *


Sec.  1.863-1  Allocation of gross income under section 863(a).

* * * * *
    (e) Residual interest in a REMIC.
    (1) REMIC inducement fees.
    (2) Excess inclusion income and net losses.
* * * * *


Sec.  1.863-1T  Allocation of gross income under section 863(a).

    (a) through (d) [Reserved].
    (e) Residual interest in a REMIC.
    (1) REMIC inducement fees.
    (2) Excess inclusion income and net losses.
    (f) Effective date.

0
Par. 8. Section 1.863-1 is amended as follows:
0
1. The paragraph heading for paragraph (e) is revised.
0
2. The text of paragraph (e) is redesignated as (e)(1).
0
3. A new paragraph heading for paragraph (e)(1) is added.
0
4. A new paragraph (e)(2) is added.
0
5. The last sentence of paragraph (f) is revised and a new sentence is 
added to the end.
    The revisions and additions read as follows:


Sec.  1.863-1  Allocation of gross income under section 863(a).

* * * * *
    (e) Residual interest in a REMIC--(1) REMIC inducement fees. * * *
    (2) Excess inclusion income and net losses. [Reserved]. For further 
guidance, see Sec.  1.863-1T(e)(2).
    (f) * * * Paragraph (e)(1) of this section is applicable for 
taxable years ending on or after May 11, 2004. For further guidance, 
see Sec.  1.863-1T(f).

0
Par. 9. Section 1.863-1T is added to read as follows:


Sec.  1.863-1T  Allocation of gross income under section 863(a) 
(temporary).

    (a) through (d) [Reserved]. For further guidance, see Sec.  1.863-
1(a) through (d).
    (e) Residual interest in a REMIC--(1) REMIC inducement fees. 
[Reserved]. For further guidance, see Sec.  1.863-1(e)(1).
    (2) Excess inclusion income and net losses. An excess inclusion (as 
defined in section 860E(c)) shall be treated as income from sources 
within the United States. To the extent of excess inclusion income 
previously taken into account with respect to a residual interest 
(reduced by net losses previously taken into account under this 
paragraph), a net loss (described in section 860C(b)(2)) with respect 
to the residual interest shall be allocated to the class of gross 
income and apportioned to the statutory grouping(s) or residual 
grouping of gross income to which the excess inclusion income was 
assigned.
    (f) Effective date. Paragraph (e)(2) of this section applies for 
taxable years ending after August 1, 2006. For further guidance, see 
Sec.  1.863-1(f). This section will expire July 31, 2009.

0
Par. 10. Section 1.1441-0 is amended by adding entries for Sec. Sec.  
1.1441-2(b)(5), 1.1441-2(d)(4), and 1.1441-2T to read as follows:


Sec.  1.1441-0  Outline of regulation provisions for section 1441.

* * * * *


Sec.  1.1441-2  Amounts subject to withholding.

* * * * *
    (b) * * *
    (5) REMIC residual interests.
* * * * *
    (d) * * *
    (4) Withholding exemption inapplicable.
* * * * *


Sec.  1.1441-2T  Amounts subject to withholding.

    (a) through (b)(4) [Reserved].
    (5) REMIC residual interests.
    (c) through (d)(3) [Reserved].
    (d)(4) Withholding exemption inapplicable.
    (e) [Reserved]
    (f) Effective date.
* * * * *

0
Par. 11. Section 1.1441-2 is amended by adding paragraphs (b)(5) and 
(d)(4), and a sentence to the end of paragraph (f), to read as follows:


Sec.  1.1441-2  Amounts subject to withholding.

* * * * *
    (b) * * *
    (5) REMIC residual interest. [Reserved]. For further guidance, see 
Sec.  1.1441-2T(b)(5).
* * * * *
    (d) * * *
    (4) Withholding exemption inapplicable. For further guidance, see 
Sec.  1.1441-2T(d)(4).
* * * * *
    (f) * * * For further guidance, see Sec.  1.1441-2T(f).

0
Par. 12. Section 1.1441-2T is added to read as follows:


Sec.  1.1441-2T  Amounts subject to withholding (temporary).

    (a) through (b)(4) [Reserved]. For further guidance, see Sec.  
1.1441-2(a) through (b)(4).
    (5) REMIC residual interests. Amounts subject to withholding 
include an excess inclusion described in Sec.  1.860G-3T(b)(2) and the 
portion of an amount described in Sec.  1.860G-3T(b)(1) that is an 
excess inclusion.
    (c) through (d)(3) [Reserved]. For further guidance, see Sec.  
1.1441-2 (c) through (d)(3).
    (4) Withholding exemption inapplicable. The exemption in Sec.  
1.1441-2(d) from the obligation to withhold shall not apply to amounts 
described in Sec.  1.860G-3T(b)(1) (regarding certain partnership 
allocations of REMIC net income with respect to a REMIC residual 
interest).
    (e) [Reserved]. For further guidance, see Sec.  1.1441-2(e).
    (f) Effective date. This section applies after August 1, 2006. This 
section will expire July 31, 2009.

Mark E. Matthews,
Deputy Commissioner for Services and Enforcement.
    Approved: July 14, 2006.
Eric Solomon,
Acting Deputy Assistant Secretary of the Treasury.
[FR Doc. E6-12363 Filed 7-31-06; 8:45 am]
BILLING CODE 4830-01-P