Stock Transfer Rules: Carryover of Earnings and Taxes; Correction, 70875-70876 [E6-20728]
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Federal Register / Vol. 71, No. 235 / Thursday, December 7, 2006 / Rules and Regulations
document, the March 29, 2005, IFR is of
a type that does not individually or
cumulatively have a significant effect on
the human environment. Therefore,
neither an environmental assessment
nor an environmental impact statement
is required.
VI. Opportunity for Public Comment
Under 5 U.S.C. 553(b)(B) and 21 CFR
10.40(e), FDA found in the March 29,
2005, IFR that providing for notice and
public comment before the
establishment of these fees, and for
revising the basis on which these fees
are calculated, is contrary to the public
interest (70 FR 15755 at 15756). FDA
continues to find it necessary to
implement the amended fee increase as
soon as possible to preserve adequate
funds for the program. The agency
believes, however, that it is appropriate
to invite and consider additional public
comments on these requirements. Any
comments already received by FDA on
the March 29, 2005, IFR do not need to
be resubmitted to the agency. The
agency is considering them at this time
and will address them at a later date.
Interested persons may submit to the
Division of Dockets Management (see
ADDRESSES) written or electronic
comments regarding this document.
Submit a single copy of electronic
comments or two paper copies of any
mailed comments, except that
individuals may submit one paper copy.
Comments are to be identified with the
docket number found in brackets in the
heading of this document. Received
comments may be seen in the Division
of Dockets Management between 9 a.m.
and 4 p.m., Monday through Friday.
List of Subjects in 21 CFR Part 80
Color additives, Cosmetics, Drugs,
Reporting and recordkeeping
requirements.
(2) Over 100 pounds but not over
1,000 pounds—$35 plus $0.06 for each
pound over 100 pounds.
*
*
*
*
*
Dated: November 29, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6–20800 Filed 12–6–06; 8:45 am]
BILLING CODE 4160–01–S
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read, in part, as
follows:
n
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.41–6 is amended by
revising paragraph (j)(2), last sentence to
read as follows:
n
§ 1.41–6
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
70875
Aggregation of expenditures.
(j) * * *
(2) * * * For taxable years ending on
or after May 24, 2005, and before
November 9, 2006, see § 1.41–6T(d) as
contained in 26 CFR part 1, revised
April 1, 2006.
Par. 3. Section 1.41–8 is amended by
revising paragraph (b)(5), last sentence
to read as follows:
n
[TD 9296]
RIN 1545–BD60
Credit for Increasing Research
Activities; Correction
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
SUMMARY: This document contains
corrections to final regulations (TD
9296) that were published in the
Federal Register on Thursday,
November 9, 2006 (71 FR 65722)
relating to the computation and
allocation of the credit for increasing
research activities for members of a
controlled group of corporations or a
group of trades or businesses under
common control.
DATES: This correction is effective
November 9, 2006.
FOR FURTHER INFORMATION CONTACT:
Nicole R. Cimino (202) 622–3120 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
§ 1.41–8 Special rules for taxable years
ending on or after November 9, 2006.
(b) * * *
(5) * * * For taxable years ending on
or after May 24, 2005, and before
November 9, 2006, see § 1.41–8T(b)(5)
as contained in 26 CFR part 1, revised
April 1, 2006.
LaNita Van Dyke,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. E6–20732 Filed 12–6–06; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9273]
RIN 1545–AX65
Therefore, under the Federal Food,
Drug, and Cosmetic Act and under
authority delegated to the Commissioner
of Food and Drugs, 21 CFR part 80 is
amended as follows:
Background
Stock Transfer Rules: Carryover of
Earnings and Taxes; Correction
The final regulations that are the
subject of this correction are under
section 41 of the Internal Revenue Code.
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
PART 80—COLOR ADDITIVE
CERTIFICATION
As published, final regulations (TD
9296) contain errors that may prove to
be misleading and are in need of
clarification.
n
1. The authority citation for 21 CFR
part 80 continues to read as follows:
n
Authority: 21 U.S.C. 371, 379e.
2. Section 80.10 is amended by
revising paragraph (b) (2) to read as
follows:
sroberts on PROD1PC70 with RULES
n
§ 80.10
*
Fees for certification services.
*
*
(b) * * *
VerDate Aug<31>2005
*
*
20:43 Dec 06, 2006
Jkt 211001
Need for Correction
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
amendments:
n
PO 00000
Frm 00021
Fmt 4700
Sfmt 4700
SUMMARY: This document contains
correction to final regulations (TD 9273)
that were published in the Federal
Register on Tuesday, August 8, 2006 (71
FR 44887) addressing the carryover of
certain tax attributes, such as earnings
and profits and foreign income tax
accounts, when two corporations
combine in a corporate reorganization or
liquidation that is described in both
section 367(b) and section 381 of the
Internal Revenue Code.
DATES: The correction is effective
August 8, 2006.
E:\FR\FM\07DER1.SGM
07DER1
70876
Federal Register / Vol. 71, No. 235 / Thursday, December 7, 2006 / Rules and Regulations
(f) * * *
(1) * * *
(iii) * * *
Correction of Publication
FOR FURTHER INFORMATION CONTACT:
Jeffrey L. Parry, (202) 622–3850 (not a
toll-free number).
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
n
SUPPLEMENTARY INFORMATION:
Background
PART 1—INCOME TAXES
The final regulations that are the
subject of this correction are under
sections 367(b) and 381 of the Internal
Revenue Code.
n
Need for Correction
Paragraph 1. The authority citation
for part 1 continues to read, in part, as
follows:
Authority: 26 U.S.C. 7805 * * *
Par. 7. Section 1.367(b)–7(f)(1)(iii)
Example 1 (iii) is amended by
revising the last sentence of paragraph
(A) and paragraph (B) to read as follows:
n
As published, final regulations (TD
9273) contain errors that may prove to
be misleading and are in need of
clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
§ 1.367(b)–7 Carryover of earnings and
profits and foreign income taxes in certain
foreign-to-foreign non-recognition
transactions.
*
*
*
*
*
Example 1 * * *
(A) * * * The 100u offset under section
952(c)(1)(B) does not result in a reduction of
the hovering deficit for purposes of section
316 or section 902.
(B) Foreign surviving corporation A’s 100u
of subpart F income not included in income
by USP will accumulate and be added to its
post-1986 undistributed earnings as of the
beginning of 2009. This 100u of posttransaction earnings will be offset by the
(100u) hovering deficit. Because the amount
of earnings offset by the hovering deficit is
100% of the total amount of the hovering
deficit, all $25 of the related taxes are added
to the post-1986 foreign income taxes pool as
well. Accordingly, foreign surviving
corporation A has the following post-1986
undistributed earnings and post-1986 foreign
income taxes on January 1, 2009:
Earnings & profits
Foreign taxes
Separate category
Positive
E&P
Hovering
deficit
Foreign
taxes
available
Foreign
taxes associated with
hovering
deficit
General ............................................................................................................................
0u
(0u)
$45
$0
*
*
*
*
*
LaNita Van Dyke,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. E6–20728 Filed 12–6–06; 8:45 am]
BILLING CODE 4830–01–P
FOR FURTHER INFORMATION CONTACT:
Concerning §§ 1.199–2T(e)(2) and
1.199–8T(i)(5), Paul Handleman or
Lauren Ross Taylor, (202) 622–3040;
concerning §§ 1.199–3T(i)(7) and (8),
and 1.199–5T, Martin Schaffer, (202)
622–3080; and concerning §§ 1.199–
7T(b)(4) and 1.199–8T(i)(6), Ken Cohen,
(202) 622–7790 (not toll-free numbers).
DEPARTMENT OF THE TREASURY
SUPPLEMENTARY INFORMATION:
Internal Revenue Service
Background
The final and temporary regulations
that are the subject of this correction are
under section 199 of the Internal
Revenue Code.
26 CFR Part 1
[TD 9293]
RIN 1545–BF88
Need for Correction
TIPRA Amendments to Section 199;
Correction
sroberts on PROD1PC70 with RULES
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
SUMMARY: This document contains
corrections to final and temporary
regulations (TD 9293) that were
published in the Federal Register on
Thursday, October 19, 2006 (71 FR
61662) concerning the amendments
made by the Tax Increase Prevention
and Reconciliation Act of 2005 to
section 199 of the Internal Revenue
Code.
DATES: This correction is effective
October 19, 2006.
VerDate Aug<31>2005
20:43 Dec 06, 2006
Jkt 211001
As published, final and temporary
regulations (TD 9293) contain errors that
may prove to be misleading and are in
need of clarification.
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
amendments:
n
Paragraph 1. The authority citation
for part 1 is amended by adding entries
PO 00000
Frm 00022
Fmt 4700
Sfmt 4700
Authority: 26 U.S.C. 7805 * * *
Section 1.199–5T also issued under 26
U.S.C. 199(d). * * *
Section 1.199–7T also issued under 26
U.S.C. 199(d). * * *
Par. 4. Section 1.199–2T(e)(2) is
amended by revising the eleventh
sentence of Example 2 paragraph (i) and
the seventh sentence of Example 5
paragraph (iv) to read as follows:
n
§ 1.199–2T
Wage limitation (temporary).
Example 2. * * *
(i) * * * For Y’s taxable year ending April
30, 2011, the total square footage of Y’s
headquarters is 8,000 square feet, of which
2,000 square feet is set aside for domestic
production activities. * * *
Example 5. * * *
(iv) * * * The EAG’s tentative section 199
deduction is $360,000 (.09 × (lesser of
combined QPAI of $4,000,000 (B’s QPAI of
$4,000,000 + S’s QPAI of $0) or combined
taxable income of $4,200,000 (B’s taxable
income of $4,000,000 + S’s taxable income of
$200,000))) subject to the W–2 wage
limitation of $50,000 (50% × ($100,000 (B’s
W–2 wages) + $0 (S’s W–2 wages))). * * *
Par. 8. Section 1.199–5T is amended
by revising sentences eight through ten
of paragraph (e)(4)(ii)(A) and revising
paragraph (g) to read as follows:
n
PART 1—INCOME TAXES
n
in numerical order to read in part as
follows:
E:\FR\FM\07DER1.SGM
07DER1
]]>Agencies
[Federal Register Volume 71, Number 235 (Thursday, December 7, 2006)]
[Rules and Regulations]
[Pages 70875-70876]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-20728]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9273]
RIN 1545-AX65
Stock Transfer Rules: Carryover of Earnings and Taxes; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendments.
-----------------------------------------------------------------------
SUMMARY: This document contains correction to final regulations (TD
9273) that were published in the Federal Register on Tuesday, August 8,
2006 (71 FR 44887) addressing the carryover of certain tax attributes,
such as earnings and profits and foreign income tax accounts, when two
corporations combine in a corporate reorganization or liquidation that
is described in both section 367(b) and section 381 of the Internal
Revenue Code.
DATES: The correction is effective August 8, 2006.
[[Page 70876]]
FOR FURTHER INFORMATION CONTACT: Jeffrey L. Parry, (202) 622-3850 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the subject of this correction are
under sections 367(b) and 381 of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9273) contain errors that may
prove to be misleading and are in need of clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Correction of Publication
0
Accordingly, 26 CFR part 1 is corrected by making the following
correcting amendments:
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. 7. Section 1.367(b)-7(f)(1)(iii)
Example 1 (iii) is amended by revising the last sentence of
paragraph (A) and paragraph (B) to read as follows:
Sec. 1.367(b)-7 Carryover of earnings and profits and foreign income
taxes in certain foreign-to-foreign non-recognition transactions.
* * * * *
(f) * * *
(1) * * *
(iii) * * *
Example 1 * * *
(A) * * * The 100u offset under section 952(c)(1)(B) does not
result in a reduction of the hovering deficit for purposes of
section 316 or section 902.
(B) Foreign surviving corporation A's 100u of subpart F income
not included in income by USP will accumulate and be added to its
post-1986 undistributed earnings as of the beginning of 2009. This
100u of post-transaction earnings will be offset by the (100u)
hovering deficit. Because the amount of earnings offset by the
hovering deficit is 100% of the total amount of the hovering
deficit, all $25 of the related taxes are added to the post-1986
foreign income taxes pool as well. Accordingly, foreign surviving
corporation A has the following post-1986 undistributed earnings and
post-1986 foreign income taxes on January 1, 2009:
----------------------------------------------------------------------------------------------------------------
Earnings & profits Foreign taxes
-------------------------------------------------------
Foreign
taxes
Separate category Hovering Foreign associated
Positive E&P deficit taxes with
available hovering
deficit
----------------------------------------------------------------------------------------------------------------
General................................................. 0u (0u) $45 $0
----------------------------------------------------------------------------------------------------------------
* * * * *
LaNita Van Dyke,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. E6-20728 Filed 12-6-06; 8:45 am]
BILLING CODE 4830-01-P
