Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d), 72645-72646 [E7-24783]
Download as PDF
<![CDATA[
Federal Register / Vol. 72, No. 245 / Friday, December 21, 2007 / Proposed Rules
§ 416.1204 Deeming of resources of the
sponsor of an alien.
The resources of an alien who first
applies for SSI benefits after September
30, 1980, are deemed to include the
resources of the alien’s sponsor for 3
years after the alien’s date of admission
into the United States. The date of
admission is the date established by the
U.S. Citizenship and Immigration
Services as the date the alien is
admitted for permanent residence.
*
*
*
*
*
Subpart R—[Amended]
7. The authority citation for subpart R
of part 416 continues to read as follows:
Authority: Secs. 702(a)(5), 1612(b),
1614(b), (c), and (d), and 1631(d)(1) and (e)
of the Social Security Act (42 U.S.C.
902(a)(5), 1382a(b), 1382c(b), (c), and (d), and
1383(d)(1) and (e)).
8. Amend § 416.1851 by revising the
first sentence of paragraph (c) and
adding a new second sentence to read
as follows:
§ 416.1851
child.
Effects of being considered a
*
*
*
*
*
(c) If you are under age 18 and live
with your parent(s) who is not eligible
for SSI benefits, we consider (deem) part
of his or her income and resources to be
your own. If you are under age 18 and
live with both your parent and your
parent’s spouse (stepparent) and neither
is eligible for SSI benefits, we consider
(deem) part of their income and
resources to be your own.
*
*
*
*
*
[FR Doc. E7–24787 Filed 12–20–07; 8:45 am]
BILLING CODE 4191–02–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–114126–07]
RIN 1545–BG54
Reduction of Foreign Tax Credit
Limitation Categories Under Section
904(d)
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking
by cross-reference to temporary
regulations and notice of public hearing.
pwalker on PROD1PC71 with PROPOSALS
AGENCY:
SUMMARY: In the Rules and Regulations
section in this issue of the Federal
Register, the IRS is issuing temporary
regulations that provide guidance
VerDate Aug<31>2005
17:13 Dec 20, 2007
Jkt 214001
relating to the reduction of the number
of separate foreign tax credit limitation
categories under section 904(d) of the
Internal Revenue Code. Changes to the
applicable law were made by the
American Jobs Creation Act of 2004
(AJCA) reducing the number of section
904(d) separate categories from eight to
two, effective for taxable years
beginning after December 31, 2006. The
temporary regulations provide guidance
needed to comply with these changes
and affect individuals and corporations
claiming foreign tax credits. The text of
those temporary regulations published
in this issue of the Federal Register also
serves as the text of these proposed
regulations. This document also
provides a notice of public hearing on
these proposed regulations.
DATES: Written or electronic comments
must be received by March 20, 2008.
Outlines of topics to be discussed at the
public hearing scheduled for April 22,
2008, at 10 a.m. must be received by
April 1, 2008.
ADDRESSES: Send submissions to
CC:PA:LPD:PR (REG–114126–07), 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–114126–
07), Courier’s desk, Internal Revenue
Service, 1111 Constitution Avenue,
NW., Washington, DC 20044, or sent
electronically, via the Federal
eRulemaking Portal at
www.regulations.gov (IRS REG–114126–
07). The public hearing will be held in
the IRS Auditorium, Internal Revenue
Building, 1111 Constitution Avenue,
NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT:
Concerning the regulations, Jeffrey L.
Parry, (202) 622–3850; concerning
submissions of comments, the hearing,
and/or to be placed on the building
access list to attend the hearing, 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 contain
amendments to the Income Tax
Regulations (26 CFR Part 1) which
provide rules relating to the reduction of
the number of separate foreign tax credit
limitation categories under section
904(d). The text of those regulations also
serves as the text of these proposed
regulations. The preamble to the
temporary regulations explains the
PO 00000
Frm 00014
Fmt 4702
Sfmt 4702
72645
temporary regulations and these
proposed regulations. The regulations
affect individuals and corporations
claiming foreign tax credits.
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 these regulations, and because the
regulations do not impose a collection
of information on small entities, the
Regulatory Flexibility Act (5 U.S.C.
chapter 6) does not apply. Pursuant to
section 7805(f), these regulations have
been submitted to the Chief Counsel for
Advocacy of the Small Business
Administration for comment on its
impact on small business.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations,
consideration will be given to any
electronic or written comments (a
signed original and eight (8) copies) that
are submitted timely to the IRS. The
Treasury Department and the IRS
specifically request comments on the
clarity of the proposed regulations and
how they may be made easier to
understand, as well as comments on
additional guidance that may be needed
to implement changes made by the
AJCA. All comments will be available
for public inspection and copying.
A public hearing has been scheduled
for April 26, 2008, in the auditorium,
Internal Revenue Building, 1111
Constitution Avenue, NW., Washington,
DC. Due to building security
procedures, visitors must enter at the
Constitution Avenue entrance. In
addition, all visitors must present photo
identification to enter the building.
Because of access restrictions, visitors
will not be admitted beyond the
immediate entrance more than 30
minutes before the hearing starts. For
information about having your name
placed on the building access list to
attend the hearing, see the FOR FURTHER
INFORMATION CONTACT section of this
preamble.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing. Persons who wish
to present oral comments at the hearing
must submit electronic or written
comments by March 20, 2008 and an
outline of the topics to be discussed and
the time to be devoted to each topic
(signed original and eight (8) copies) by
April 1, 2008. A period of 10 minutes
E:\FR\FM\21DEP1.SGM
21DEP1
72646
Federal Register / Vol. 72, No. 245 / Friday, December 21, 2007 / Proposed Rules
will be allotted to each person for
making comments.
An agenda showing the scheduling of
the speakers will be prepared after the
deadline for receiving outlines has
passed. Copies of the agenda will be
available free of charge at the hearing.
Drafting Information
The principal author of these
regulations is Jeffrey L. Parry of the
Office of Chief Counsel (International).
However, other personnel from the
Treasury Department and the IRS
participated in their development.
*
*
*
*
(h) * * *
(3) [The text of the proposed
amendment to § 1.904–5(h)(3) is the
same as the text of § 1.904–5T(h)(3)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(o) * * *
(3) [The text of proposed § 1.904–
5(o)(3) is the same as the text of § 1.904–
5T(o)(3) published elsewhere in this
issue of the Federal Register.]
Par. 5. Section 1.904–7(g) is added to
read as follows:
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 1.904–2(i) is added to
read as follows:
§ 1.904–2 Carryback and carryover of
unused foreign tax.
*
*
*
*
*
(i) [The text of proposed § 1.904–2(i)
is the same as the text of § 1.904–
2T(i)(1) through (3) published elsewhere
in this issue of the Federal Register.]
Par. 3. In § 1.904–4, paragraphs (a),
(b), (h)(3), and (l) are revised and
paragraph (n) is added to read as
follows:
pwalker on PROD1PC71 with PROPOSALS
§ 1.904–4 Separate application of section
904 with respect to certain categories of
income.
(a) [The text of the proposed
amendment to § 1.904–4(a) is the same
as the text of § 1.904–4T(a) published
elsewhere in this issue of the Federal
Register.]
(b) [The text of the proposed
amendment to § 1.904–4(b) is the same
as the text of § 1.904–4T(b) published
elsewhere in this issue of the Federal
Register.]
*
*
*
*
*
(h) * * *
(3) [The text of the proposed
amendment to § 1.904–4(h)(3) is the
same as the text of § 1.904–4T(h)(3)
published elsewhere in this issue of the
Federal Register.]
*
*
*
*
*
(l) [The text of the proposed
amendment to § 1.904–4(l) is the same
17:13 Dec 20, 2007
Jkt 214001
§ 1.904–5 Look-through rules as applied to
controlled foreign corporations and other
entities.
*
List of Subjects in 26 CFR Part 1
VerDate Aug<31>2005
as the text of § 1.904–4T(l) published
elsewhere in this issue of the Federal
Register.]
*
*
*
*
*
(n) [The text of proposed § 1.904–4(n)
is the same as the text of § 1.904–4T(n)
published elsewhere in this issue of the
Federal Register.]
Par. 4. In § 1.904–5, paragraph (h)(3)
is revised and paragraph (o)(3) is added
to read as follows:
§ 1.904–7
Transition rules.
*
*
*
*
*
(g) [The text of proposed § 1.904–7(g)
is the same as the text of § 1.904–
7T(g)(1) through (6) published
elsewhere in this issue of the Federal
Register.]
Par. 6. § 1.904(f)–12(h) is added to
read as follows:
§ 1.904(f)–12
Transition rules.
*
*
*
*
*
(h) [The text of proposed § 1.904–
12(h) is the same as the text of § 1.904–
12T(h)(1) through (h)(6) published
elsewhere in this issue of the Federal
Register.]
Linda E. Stiff,
Deputy Commissioner for Services and
Enforcement.
[FR Doc. E7–24783 Filed 12–20–07; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–141399–07]
RIN 1545–BH13
Treatment of Overall Foreign and
Domestic Losses
Internal Revenue Service (IRS),
Treasury.
AGENCY:
PO 00000
Frm 00015
Fmt 4702
Sfmt 4702
Notice of proposed rulemaking
by cross-reference to temporary
regulations and notice of public hearing.
ACTION:
SUMMARY: In the Rules and Regulations
section in this issue of the Federal
Register, the IRS is issuing temporary
regulations that provide guidance
relating to the recapture of overall
foreign and domestic losses. Changes to
the applicable law were made by the
American Jobs Creation Act of 2004, as
corrected by the Gulf Opportunity Zone
Act of 2005. The temporary regulations
provide guidance needed to comply
with these changes, as well as updated
guidance with respect to overall foreign
losses and separate limitation losses,
and affect individuals and corporations
claiming foreign tax credits. The text of
those temporary regulations published
in this issue of the Federal Register also
serves as the text of these proposed
regulations. This document also
provides a notice of public hearing on
these proposed regulations.
DATES: Written or electronic comments
must be received by March 20, 2008.
Outlines of topics to be discussed at the
public hearing scheduled for April 10,
2008, at 10 a.m. must be received by
March 20, 2008.
ADDRESSES: Send submissions to
CC:PA:LPD:PR (REG–141399–07), room
5203, Internal Revenue Service, PO 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–141399–07),
Courier’s desk, Internal Revenue
Service, 1111 Constitution Avenue,
NW., Washington, DC 20044, or sent
electronically, via the Federal
eRulemaking Portal at
www.regulations.gov (IRS REG–
141399–07). The public hearing will be
held in the IRS Auditorium, Internal
Revenue Building, 1111 Constitution
Avenue, NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT:
Concerning the regulations, Jeffrey L.
Parry, (202) 622–3850 (not a toll free
number); concerning submissions of
comments, the hearing, and/or to be
placed on the building access list to
attend the hearing, Richard Hurst,
Richard.A.Hurst@irscounsel.treas.gov.
SUPPLEMENTARY INFORMATION:
Background and Explanation of
Provisions
Temporary regulations in the Rules
and Regulations section of this issue of
the Federal Register amend the Income
Tax Regulations (26 CFR Part 1)
providing rules relating to the recapture
of overall domestic losses under section
E:\FR\FM\21DEP1.SGM
21DEP1
]]>Agencies
[Federal Register Volume 72, Number 245 (Friday, December 21, 2007)]
[Proposed Rules]
[Pages 72645-72646]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-24783]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-114126-07]
RIN 1545-BG54
Reduction of Foreign Tax Credit Limitation Categories Under
Section 904(d)
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking by cross-reference to temporary
regulations and notice of public hearing.
-----------------------------------------------------------------------
SUMMARY: In the Rules and Regulations section in this issue of the
Federal Register, the IRS is issuing temporary regulations that provide
guidance relating to the reduction of the number of separate foreign
tax credit limitation categories under section 904(d) of the Internal
Revenue Code. Changes to the applicable law were made by the American
Jobs Creation Act of 2004 (AJCA) reducing the number of section 904(d)
separate categories from eight to two, effective for taxable years
beginning after December 31, 2006. The temporary regulations provide
guidance needed to comply with these changes and affect individuals and
corporations claiming foreign tax credits. The text of those temporary
regulations published in this issue of the Federal Register also serves
as the text of these proposed regulations. This document also provides
a notice of public hearing on these proposed regulations.
DATES: Written or electronic comments must be received by March 20,
2008. Outlines of topics to be discussed at the public hearing
scheduled for April 22, 2008, at 10 a.m. must be received by April 1,
2008.
ADDRESSES: Send submissions to CC:PA:LPD:PR (REG-114126-07), 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-
114126-07), Courier's desk, Internal Revenue Service, 1111 Constitution
Avenue, NW., Washington, DC 20044, or sent electronically, via the
Federal eRulemaking Portal at www.regulations.gov (IRS REG-114126-07).
The public hearing will be held in the IRS Auditorium, Internal Revenue
Building, 1111 Constitution Avenue, NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Jeffrey L.
Parry, (202) 622-3850; concerning submissions of comments, the hearing,
and/or to be placed on the building access list to attend the hearing,
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 contain amendments to the Income Tax
Regulations (26 CFR Part 1) which provide rules relating to the
reduction of the number of separate foreign tax credit limitation
categories under section 904(d). The text of those regulations also
serves as the text of these proposed regulations. The preamble to the
temporary regulations explains the temporary regulations and these
proposed regulations. The regulations affect individuals and
corporations claiming foreign tax credits.
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 these regulations, and because
the regulations do not impose a collection of information on small
entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not
apply. Pursuant to section 7805(f), these regulations have been
submitted to the Chief Counsel for Advocacy of the Small Business
Administration for comment on its impact on small business.
Comments and Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any electronic or written comments (a
signed original and eight (8) copies) that are submitted timely to the
IRS. The Treasury Department and the IRS specifically request comments
on the clarity of the proposed regulations and how they may be made
easier to understand, as well as comments on additional guidance that
may be needed to implement changes made by the AJCA. All comments will
be available for public inspection and copying.
A public hearing has been scheduled for April 26, 2008, in the
auditorium, Internal Revenue Building, 1111 Constitution Avenue, NW.,
Washington, DC. Due to building security procedures, visitors must
enter at the Constitution Avenue entrance. In addition, all visitors
must present photo identification to enter the building. Because of
access restrictions, visitors will not be admitted beyond the immediate
entrance more than 30 minutes before the hearing starts. For
information about having your name placed on the building access list
to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section
of this preamble.
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments at the hearing must submit electronic or
written comments by March 20, 2008 and an outline of the topics to be
discussed and the time to be devoted to each topic (signed original and
eight (8) copies) by April 1, 2008. A period of 10 minutes
[[Page 72646]]
will be allotted to each person for making comments.
An agenda showing the scheduling of the speakers will be prepared
after the deadline for receiving outlines has passed. Copies of the
agenda will be available free of charge at the hearing.
Drafting Information
The principal author of these regulations is Jeffrey L. Parry of
the Office of Chief Counsel (International). However, 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 1.904-2(i) is added to read as follows:
Sec. 1.904-2 Carryback and carryover of unused foreign tax.
* * * * *
(i) [The text of proposed Sec. 1.904-2(i) is the same as the text
of Sec. 1.904-2T(i)(1) through (3) published elsewhere in this issue
of the Federal Register.]
Par. 3. In Sec. 1.904-4, paragraphs (a), (b), (h)(3), and (l) are
revised and paragraph (n) is added to read as follows:
Sec. 1.904-4 Separate application of section 904 with respect to
certain categories of income.
(a) [The text of the proposed amendment to Sec. 1.904-4(a) is the
same as the text of Sec. 1.904-4T(a) published elsewhere in this issue
of the Federal Register.]
(b) [The text of the proposed amendment to Sec. 1.904-4(b) is the
same as the text of Sec. 1.904-4T(b) published elsewhere in this issue
of the Federal Register.]
* * * * *
(h) * * *
(3) [The text of the proposed amendment to Sec. 1.904-4(h)(3) is
the same as the text of Sec. 1.904-4T(h)(3) published elsewhere in
this issue of the Federal Register.]
* * * * *
(l) [The text of the proposed amendment to Sec. 1.904-4(l) is the
same as the text of Sec. 1.904-4T(l) published elsewhere in this issue
of the Federal Register.]
* * * * *
(n) [The text of proposed Sec. 1.904-4(n) is the same as the text
of Sec. 1.904-4T(n) published elsewhere in this issue of the Federal
Register.]
Par. 4. In Sec. 1.904-5, paragraph (h)(3) is revised and paragraph
(o)(3) is added to read as follows:
Sec. 1.904-5 Look-through rules as applied to controlled foreign
corporations and other entities.
* * * * *
(h) * * *
(3) [The text of the proposed amendment to Sec. 1.904-5(h)(3) is
the same as the text of Sec. 1.904-5T(h)(3) published elsewhere in
this issue of the Federal Register.]
* * * * *
(o) * * *
(3) [The text of proposed Sec. 1.904-5(o)(3) is the same as the
text of Sec. 1.904-5T(o)(3) published elsewhere in this issue of the
Federal Register.]
Par. 5. Section 1.904-7(g) is added to read as follows:
Sec. 1.904-7 Transition rules.
* * * * *
(g) [The text of proposed Sec. 1.904-7(g) is the same as the text
of Sec. 1.904-7T(g)(1) through (6) published elsewhere in this issue
of the Federal Register.]
Par. 6. Sec. 1.904(f)-12(h) is added to read as follows:
Sec. 1.904(f)-12 Transition rules.
* * * * *
(h) [The text of proposed Sec. 1.904-12(h) is the same as the text
of Sec. 1.904-12T(h)(1) through (h)(6) published elsewhere in this
issue of the Federal Register.]
Linda E. Stiff,
Deputy Commissioner for Services and Enforcement.
[FR Doc. E7-24783 Filed 12-20-07; 8:45 am]
BILLING CODE 4830-01-P
