Guidance Necessary To Facilitate Business Electronic Filing Under Section 1561, 76955-76956 [06-9757]

Download as PDF Federal Register / Vol. 71, No. 246 / Friday, December 22, 2006 / Proposed Rules Administration order 7400.9P, Airspace Designations and Reporting Points, dated September 1, 2006, and effective September 15, 2006, is amended as follows: Paragraph 6005 Class E airspace areas extending upward from 700 feet or more above the surface of the earth. * * * * * ACE MO E5 Potosi, MO Potosi, Washington County Airport, MO (Lat. 37°55′45″ N., long. 90°43′53″ W.) That airspace extending upward from 700 feet above the surface within a 6.4-mile radius of Potosi, Washington County Airport, MO. * * * * * Issued in Fort Worth, TX, on December 11, 2006. Donald R. Smith, Manager, System Support Group, ATO Central Service Area. [FR Doc. 06–9827 Filed 12–21–06; 8:45 am] Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–161919– 05), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC, or sent electronically, via the IRS Internet site at http://www.irs.gov/regs or via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG–161919–05). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Grid Glyer, (202) 622–7930, concerning submissions of comments and requests for public hearings, Kelly Banks (202) 622–7180 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background and Explanation of Provisions [REG–161919–05] Temporary regulations in the Rules and Regulations section of this issue of the Federal Register amend 26 CFR part 1 to add §§ 1.1502–43T, 1.1561–1T, 1.1561–2T and 1.1561–3T, and amend §§ 1.1502–47T and 1.1563–1T. The text of those temporary regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the amendments. RIN 1545–BF25 Special Analyses BILLING CODE 4910–13–M DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 Guidance Necessary To Facilitate Business Electronic Filing Under Section 1561 Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations. AGENCY: In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that affect component members of controlled groups of corporations and consolidated groups filing life-nonlife Federal income tax returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type of information these members are required to submit with their returns. The text of those regulations also serves as the text of these proposed regulations. ycherry on PROD1PC64 with PROPOSALS SUMMARY: Written or electronic comments, and a request for a public hearing, must be received by March 22, 2007. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG–161919–05), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, DATES: VerDate Aug<31>2005 15:42 Dec 21, 2006 Jkt 211001 It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to the following proposed regulations, §§ 1.1561–1, 1.1561–3 and 1.1563–1, and because these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. With respect to the following proposed regulations, §§ 1.1502–43, 1.1502–47 and 1.1561–2, it is hereby certified that these regulations will not have a significant economic impact on a substantial number of small entities. This certification is based on the fact that these regulations primarily affect large corporations (which are members of either controlled or consolidated groups). Therefore, a regulatory flexibility analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, this notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business. PO 00000 Frm 00006 Fmt 4702 Sfmt 4702 76955 Comments and Requests for a Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any written comments (a signed original and eight (8) copies) or electronic comments that are submitted timely to the IRS. All comments will be available for public inspection and copying. A public hearing may be scheduled if requested in writing by any person that timely submits written or electronic comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register. Drafting Information The principal author of these regulations is Grid Glyer of the Office of Associate Chief Counsel (Corporate). Other personnel from the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Proposed Amendments to the Regulations Accordingly, 26 CFR part 1 is proposed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read, in part, as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.1502–43 is amended by revising paragraph (d) and adding paragraph (e) to read as follows: § 1.1502–43 Consolidated accumulated earnings tax. [The text of the proposed amendment to § 1.1502–43 is the same as the text for § 1.1502–43T published elsewhere in this issue of the Federal Register]. Par. 3. Section 1.1502–47 is amended by revising paragraph (s) and adding paragraph (t) to read as follows: § 1.1502–47 Consolidated returns by lifenonlife groups. [The text of the proposed amendment to § 1.1502–47 is the same as the text for § 1.1502–47T published elsewhere in this issue of the Federal Register]. Par. 4. Section 1.1561–1 is added to read as follows: § 1.1561–1 General rules regarding certain tax benefits available to the component members of a controlled group of corporations. [The text of the proposed § 1.1561–1 is the same as the text for § 1.1561–1T E:\FR\FM\22DEP1.SGM 22DEP1 76956 Federal Register / Vol. 71, No. 246 / Friday, December 22, 2006 / Proposed Rules published elsewhere in this issue of the Federal Register]. Par. 5. Section 1.1561–2 is amended by revising paragraphs (a), (b), (c) and (d) and adding paragraph (f) to read as follows: § 1.1561–2 benefits. Determination of amount of tax [The text of the proposed amendment to § 1.1561–2 is the same as the text for 1.1561–2T published elsewhere in this issue of the Federal Register]. Par. 6. Section 1.1561–3 is added to read as follows: § 1.1561–3 tax items. Allocating the section 1561(a) [The text of the proposed § 1.1561–3 is the same as the text for § 1.1561–3T published elsewhere in this issue of the Federal Register]. Par. 7. Section 1.1563–1 is added to read as follows: § 1.1563–1 Definition of controlled group of corporations and component members. [The text of the proposed § 1.1563–1 is the same as the text for § 1.1563–1T published elsewhere in this issue of the Federal Register]. Mark E. Matthews, Deputy Commissioner for Services and Enforcement. [FR Doc. 06–9757 Filed 12–21–06; 8:45 am] BILLING CODE 4830–01–P transactions under section 482. These regulations also provide guidance regarding the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party, as it relates to controlled services transactions, and modify the regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482. FOR FURTHER INFORMATION CONTACT: Thomas A. Vidano, (202) 435–5265, or Carol B. Tan (202) 435–5159, for matters relating to section 482, and David F. Bergkuist, (202) 622–3850, for matters relating to stewardship expenses (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background The notice of proposed rulemaking (REG–146893–02, REG–115037–00 and REG–138603–03) by cross-reference to temporary regulations that is the subject of this correction is under section 482 and 861 of the Internal Revenue Code. Need for Correction As published, the notice of proposed rulemaking (REG–146893–02, REG– 115037–00 and REG–138603–03) by cross-reference to temporary regulations contains errors that may prove to be misleading and are in need of clarification. DEPARTMENT OF THE TREASURY Accordingly, the notice of proposed rulemaking (REG–146893–02, REG– 138603–03 and REG–115037–00) by cross-reference to temporary regulations that were the subject of FR Doc. 06– 6674, is corrected as follows: 1. On page 44247, column 2, in the heading, the subject ‘‘Treatment of Services Under Section 482 Allocation of Income and Deductions From Intangibles Stewardship Expense’’ is corrected to read, ‘‘Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; and Apportionment of Stewardship Expense’’. 2. On page 44248, column 2, instructional Par. 3., number 2 is corrected to read as follows: ‘‘2. Paragraphs (d)(3)(ii)(C), Example 4, Example 5, Example 6 and (j)(6) are added.’’ 26 CFR Part 1 [REG–146893–02; REG–115037–00; REG– 138603–03] RIN 1545–BB31, 1545–AY38, 1545–BC52 Treatment of Services Under Section 482 Allocation of Income and Deductions From Intangibles Stewardship Expense; Correction Internal Revenue Service (IRS), Treasury. ACTION: Correction to notice of proposed rulemaking by cross-reference to temporary regulations, notice of proposed rulemaking, and notice of public hearing. AGENCY: ycherry on PROD1PC64 with PROPOSALS § 1.482–8 [Corrected] 4. On page 44249, column 2, § 1.482– 8(a), line 1, the language ‘‘(a) Example 10. Cost of services plus’’ is corrected to read ‘‘(b) * * * Example 10. Cost of services plus’’. 5. On page 44249, column 2, § 1.482– 8, paragraph (b) following Example 12. is removed. § 1.482–9 [Corrected] 6. On page 44249, column 2, § 1.482– 9(m)(6), last line, the language ‘‘operation as defined in § 1.482–8’’ is corrected to read ‘‘operation as defined in the proposed § 1.482–8.’’. § 1.861–8 [Corrected] 7. On page 44249, column 3, § 1.861– 8(f)(4), line 3, the language ‘‘same as the text of § 1.861–8T(c)(4)(i)’’ is corrected to read ‘‘same as the text of § 1.861– 8T(f)(4)(i)’’. 8. On page 44249, column 3, § 1.861– 8(h), line 3, the language ‘‘as the text of § 1.861–8T(h)(1) published’’ is corrected to read ‘‘as the text of § 1.861–8T(h) published’’. Cynthia Grigsby, Senior Federal Register Liaison Officer, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. E6–21909 Filed 12–21–06; 8:45 am] BILLING CODE 4830–01–P Correction of Publication Internal Revenue Service § 1.482–1(j)(6) is the same as the text of § 1.482–1T(j)(6)’’. SUMMARY: This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations, notice of proposed rulemaking, and notice of public hearing that was published in the Federal Register on Friday, August 4, 2006 (71 FR 44247) relating to the treatment of controlled services VerDate Aug<31>2005 15:42 Dec 21, 2006 Jkt 211001 § 1.482–1 [Corrected] 3. On page 44248, column 3, § 1.482– 1(j), lines 2 and 3, the language ‘‘amendment to § 1.482–1(j) is the same as the text of § 1.482–1T(j)(1) and (2)’’ is corrected to read ‘‘amendment to PO 00000 Frm 00007 Fmt 4702 Sfmt 4702 ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 63 [EPA–HQ–OAR–2002–0093; FRL–8260–6] RIN 2060–AN10 National Emission Standards for Hazardous Air Pollutants: Surface Coating of Automobiles and Light-Duty Trucks Environmental Protection Agency (EPA). ACTION: Proposed rule. AGENCY: SUMMARY: On April 26, 2004, EPA issued the National Emission Standards for Hazardous Air Pollutants: Surface Coating of Automobiles and Light-Duty Trucks (Automobiles and Light-Duty Trucks NESHAP) under section 112(d) of the Clean Air Act. We are proposing to amend the final rule to provide the option of including surface coating of heavier motor vehicles under this rule. This action also proposes to amend the National Emission Standards for Hazardous Air Pollutants for Surface E:\FR\FM\22DEP1.SGM 22DEP1

Agencies

[Federal Register Volume 71, Number 246 (Friday, December 22, 2006)]
[Proposed Rules]
[Pages 76955-76956]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 06-9757]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-161919-05]
RIN 1545-BF25


Guidance Necessary To Facilitate Business Electronic Filing Under 
Section 1561

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary 
regulations.

-----------------------------------------------------------------------

SUMMARY: In the Rules and Regulations section of this issue of the 
Federal Register, the IRS is issuing temporary regulations that affect 
component members of controlled groups of corporations and consolidated 
groups filing life-nonlife Federal income tax returns. They provide 
guidance regarding the apportionment of tax benefit items and the 
amount and type of information these members are required to submit 
with their returns. The text of those regulations also serves as the 
text of these proposed regulations.

DATES: Written or electronic comments, and a request for a public 
hearing, must be received by March 22, 2007.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-161919-05), Room 
5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
161919-05), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue, NW., Washington, DC, or sent electronically, via the IRS 
Internet site at http://www.irs.gov/regs or via the Federal eRulemaking 
Portal at www.regulations.gov (indicate IRS and REG-161919-05).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Grid Glyer, (202) 622-7930, concerning submissions of comments and 
requests for public hearings, Kelly Banks (202) 622-7180 (not toll-free 
numbers).

SUPPLEMENTARY INFORMATION:

Background and Explanation of Provisions

    Temporary regulations in the Rules and Regulations section of this 
issue of the Federal Register amend 26 CFR part 1 to add Sec. Sec.  
1.1502-43T, 1.1561-1T, 1.1561-2T and 1.1561-3T, and amend Sec. Sec.  
1.1502-47T and 1.1563-1T. The text of those temporary regulations also 
serves as the text of these proposed regulations. The preamble to the 
temporary regulations explains the amendments.

Special Analyses

    It has been determined that this notice of proposed rulemaking is 
not a significant regulatory action as defined in Executive Order 
12866. Therefore, a regulatory assessment is not required. It has also 
been determined that section 553(b) of the Administrative Procedure Act 
(5 U.S.C. chapter 5) does not apply to the following proposed 
regulations, Sec. Sec.  1.1561-1, 1.1561-3 and 1.1563-1, and because 
these regulations do not impose a collection of information on small 
entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not 
apply. With respect to the following proposed regulations, Sec. Sec.  
1.1502-43, 1.1502-47 and 1.1561-2, it is hereby certified that these 
regulations will not have a significant economic impact on a 
substantial number of small entities. This certification is based on 
the fact that these regulations primarily affect large corporations 
(which are members of either controlled or consolidated groups). 
Therefore, a regulatory flexibility analysis is not required. Pursuant 
to section 7805(f) of the Internal Revenue Code, this notice of 
proposed rulemaking will be submitted to the Chief Counsel for Advocacy 
of the Small Business Administration for comment on their impact on 
small business.

Comments and Requests for a Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any written comments (a signed original 
and eight (8) copies) or electronic comments that are submitted timely 
to the IRS. All comments will be available for public inspection and 
copying. A public hearing may be scheduled if requested in writing by 
any person that timely submits written or electronic comments. If a 
public hearing is scheduled, notice of the date, time, and place for 
the public hearing will be published in the Federal Register.

Drafting Information

    The principal author of these regulations is Grid Glyer of the 
Office of Associate Chief Counsel (Corporate). Other personnel from the 
Treasury Department and the IRS participated in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

    Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read, 
in part, as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 2. Section 1.1502-43 is amended by revising paragraph (d) and 
adding paragraph (e) to read as follows:


Sec.  1.1502-43  Consolidated accumulated earnings tax.

    [The text of the proposed amendment to Sec.  1.1502-43 is the same 
as the text for Sec.  1.1502-43T published elsewhere in this issue of 
the Federal Register].
    Par. 3. Section 1.1502-47 is amended by revising paragraph (s) and 
adding paragraph (t) to read as follows:


Sec.  1.1502-47  Consolidated returns by life-nonlife groups.

    [The text of the proposed amendment to Sec.  1.1502-47 is the same 
as the text for Sec.  1.1502-47T published elsewhere in this issue of 
the Federal Register].
    Par. 4. Section 1.1561-1 is added to read as follows:


Sec.  1.1561-1  General rules regarding certain tax benefits available 
to the component members of a controlled group of corporations.

    [The text of the proposed Sec.  1.1561-1 is the same as the text 
for Sec.  1.1561-1T

[[Page 76956]]

published elsewhere in this issue of the Federal Register].
    Par. 5. Section 1.1561-2 is amended by revising paragraphs (a), 
(b), (c) and (d) and adding paragraph (f) to read as follows:


Sec.  1.1561-2  Determination of amount of tax benefits.

    [The text of the proposed amendment to Sec.  1.1561-2 is the same 
as the text for 1.1561-2T published elsewhere in this issue of the 
Federal Register].
    Par. 6. Section 1.1561-3 is added to read as follows:


Sec.  1.1561-3  Allocating the section 1561(a) tax items.

    [The text of the proposed Sec.  1.1561-3 is the same as the text 
for Sec.  1.1561-3T published elsewhere in this issue of the Federal 
Register].
    Par. 7. Section 1.1563-1 is added to read as follows:


Sec.  1.1563-1  Definition of controlled group of corporations and 
component members.

    [The text of the proposed Sec.  1.1563-1 is the same as the text 
for Sec.  1.1563-1T published elsewhere in this issue of the Federal 
Register].

Mark E. Matthews,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 06-9757 Filed 12-21-06; 8:45 am]
BILLING CODE 4830-01-P