Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles, 54541-54542 [2010-22239]

Download as PDF srobinson on DSKHWCL6B1PROD with PROPOSALS Federal Register / Vol. 75, No. 173 / Wednesday, September 8, 2010 / Proposed Rules Congress. In January 2010, the Secretary of Commerce, on the recommendation of the Secretary of State, extended for one year all foreign policy-based export controls then in effect. BIS is now soliciting public comment on the effects of extending or modifying the existing foreign policy-based export controls for another year. Among the criteria considered in determining whether to continue or revise U.S. foreign policybased export controls are the following: 1. The likelihood that such controls will achieve their intended foreign policy purposes, in light of other factors, including the availability from other countries of the goods, software or technology proposed for such controls; 2. Whether the foreign policy objective of such controls can be achieved through negotiations or other alternative means; 3. The compatibility of the controls with the foreign policy objectives of the United States and with overall U.S. policy toward the country subject to the controls; 4. Whether the reaction of other countries to the extension of such controls is not likely to render the controls ineffective in achieving the intended foreign policy objective or be counterproductive to U.S. foreign policy interests; 5. The comparative benefits to U.S. foreign policy objectives versus the effect of the controls on the export performance of the United States, the competitive position of the United States in the international economy, the international reputation of the United States as a supplier of goods and technology; and 6. The ability of the United States to effectively enforce the controls. BIS is particularly interested in receiving comments on the economic impact of proliferation controls. BIS is also interested in industry information relating to the following: 1. Information on the effect of foreign policy-based export controls on sales of U.S. products to third countries (i.e., those countries not targeted by sanctions), including the views of foreign purchasers or prospective customers regarding U.S. foreign policybased export controls. 2. Information on controls maintained by U.S. trade partners. For example, to what extent do U.S. trade partners have similar controls on goods and technology on a worldwide basis or to specific destinations? 3. Information on licensing policies or practices by our foreign trade partners that are similar to U.S. foreign policybased export controls, including license review criteria, use of conditions, and VerDate Mar<15>2010 16:36 Sep 07, 2010 Jkt 220001 requirements for pre- and post-shipment verifications (preferably supported by examples of approvals, denials and foreign regulations). 4. Suggestions for revisions to foreign policy-based export controls that would bring them more into line with multilateral practice. 5. Comments or suggestions as to actions that would make multilateral controls more effective. 6. Information that illustrates the effect of foreign policy-based export controls on trade or acquisitions by intended targets of the controls. 7. Data or other information on the effect of foreign policy-based export controls on overall trade at the level of individual industrial sectors. 8. Suggestions as to how to measure the effect of foreign policy-based export controls on trade. 9. Information on the use of foreign policy-based export controls on targeted countries, entities, or individuals. BIS is also interested in comments relating generally to the extension or revision of existing foreign policy-based export controls. Parties submitting comments are asked to be as specific as possible. All comments received before the close of the comment period will be considered by BIS in reviewing the controls and developing the report to Congress. All comments received in response to this notice will be displayed on BIS’s Freedom of Information Act (FOIA) Web site at https://www.bis.doc.gov/foia. Dated: August 30, 2010. Kevin J. Wolf, Assistant Secretary for Export Administration. [FR Doc. 2010–21955 Filed 9–7–10; 8:45 am] BILLING CODE 3510–33–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 31 [REG–146893–02, REG–115037–00] RIN 1545–BJ32 Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles Internal Revenue Service (IRS), Treasury. ACTION: Withdrawal of notice of proposed rulemaking. AGENCY: This document withdraws proposed regulations published in the Federal Register on September 10, 2003 (68 FR 53448), related to the treatment SUMMARY: PO 00000 Frm 00014 Fmt 4702 Sfmt 4702 54541 of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible that is owned by another controlled party. The IRS and Treasury Department are withdrawing those proposed regulations because they have been superseded. FOR FURTHER INFORMATION CONTACT: Gregory A. Spring (202) 435–5265 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background On September 10, 2003, the Treasury Department and the IRS published in the Federal Register (68 FR 53448, REG–146893–02 and REG–115037–00) proposed regulations relating to the treatment of controlled services transactions and the allocation of income from intangible property, in particular with respect to contributions by a controlled party to the value of intangible property owned by another controlled party. On August 4, 2006, the Treasury Department and the IRS published in the Federal Register (71 FR 44466, TD 9278, REG–146893–02, REG–115037–00, and REG–138603–03) temporary regulations relating to the treatment of controlled services transactions, the allocation of income from intangible property, and stewardship expenses under Treas. Reg. § 1.861–8(e)(4). A notice of proposed rulemaking cross-referencing the temporary regulations was published in the Federal Register on the same day (71 FR 44247). Written comments responding to the notice of proposed rulemaking were received, and a public hearing was held on October 27, 2006. That notice of proposed rulemaking superseded the proposed regulations published in the Federal Register on September 10, 2003. On August 4, 2009, the Treasury Department and the IRS published in the Federal Register (74 FR 38830, TD 9456) final regulations that are generally consistent with the proposed regulations that were published on August 4, 2006, in the Federal Register (71 FR 44247), and removed the corresponding temporary regulations. List of Subjects 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. 26 CFR Part 31 Employment taxes, Income taxes, Penalties, Pensions, Railroad retirement, Reporting and recordkeeping E:\FR\FM\08SEP1.SGM 08SEP1 54542 Federal Register / Vol. 75, No. 173 / Wednesday, September 8, 2010 / Proposed Rules requirements, Social Security, Unemployment compensation. Withdrawal of a Notice of Proposed Rulemaking Accordingly, under the authority of 26 U.S.C. 7805, the notice of proposed rulemaking (REG–146893–02 and REG– 115037–00) published in the Federal Register on September 10, 2003 (68 FR 53448) is withdrawn. Steven T. Miller, Deputy Commissioner for Services and Enforcement. [FR Doc. 2010–22239 Filed 9–7–10; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF LABOR Employee Benefits Security Administration 29 CFR Part 2570 RIN 1210–AA98 Prohibited Transaction Exemption Procedures; Employee Benefit Plans Correction In proposed rule document 2010– 21073 beginning on page 53172 in the issue of Monday, August 30, 2010, make the following correction: §2570.43 [Corrected] On page 53190, in §2570.43, in the second column, footnote 6 is corrected to read as set forth below: 6 The applicant will fill in the room number of the Office of Exemption Determinations. As of the date of this final regulation, the room number of the Office of Exemption Determinations is N–5700. [FR Doc. C1–2010–21073 Filed 9–7–10; 8:45 am] BILLING CODE 1505–01–D DEPARTMENT OF AGRICULTURE Forest Service srobinson on DSKHWCL6B1PROD with PROPOSALS 36 CFR Part 294 Special Areas; Roadless Area Conservation; Applicability to the National Forests in Idaho; Proposed Correction Forest Service, USDA. Proposed administrative correction; request for comment. AGENCY: ACTION: The Forest Service, U.S. Department of Agriculture (USDA), is proposing to make administrative corrections affecting Big Creek Fringe, SUMMARY: VerDate Mar<15>2010 16:36 Sep 07, 2010 Jkt 220001 French Creek, Placer Creek, Secesh, and Smith Creek Idaho Roadless Areas on the Payette National Forest. These corrections will remedy two errors regarding regulatory classification and mapping that concern Forest Plan Special Areas (Big Creek and French Creek). Notice is given pursuant to 36 CFR 294.27(a), that the Chief proposes to issue an administrative correction after a 30-day public notice and opportunity to comment. DATES: Comments must be received, in writing, on or before October 8, 2010. ADDRESSES: Written comments concerning this proposed administrative correction should be addressed to Idaho Roadless Area Payette Correction, Northern Region USFS, Federal Building, 200 East Broadway, P.O. Box 7669, Missoula, MT 59807–7669. Comments may also be sent via e-mail to comments-northern-regionaloffice@fs.fed.us, or via facsimile to 406– 329–3314. All comments, including names and addresses when provided, are placed in the record and are available for public inspection and copying. The public may inspect comments received at https:// roadless.fs.fed.us. FOR FURTHER INFORMATION CONTACT: Idaho Roadless Coordinator Joan Dickerson at 406–329–3314. Additional information concerning this administrative correction, including the proposed corrected maps, may be obtained on the Internet at https:// roadless.fs.fed.us. Individuals who use telecommunication devices for the deaf (TDD) may call the Federal Information Relay Service (FIRS) at 1–800–877–8339 between 8 a.m. and 8 p.m., Eastern Standard Time, Monday through Friday. SUPPLEMENTARY INFORMATION: The following correction is proposed to fix technical errors in the Idaho Roadless Area Rule published in the Federal Register October 16, 2008 (73 FR 61456) and associated maps. These corrections were discussed with the State of Idaho Implementation Committee on September 11, 2009, and no concerns were expressed by the Committee. These corrections would facilitate the development of the Big Creek Fuels Reduction Project on the Krassel Ranger District, Payette National Forest. The project is being developed to reduce fuels in the wildland urban interface around the community of Big Creek. The corrections are needed so the appropriate treatment may be designed. The public should be aware that the indexing of management themes for individual Idaho Roadless Areas set forth in § 294.29 is an approximation (to the nearest hundred acres). PO 00000 Frm 00015 Fmt 4702 Sfmt 4702 Corrections Regarding Big Creek The Idaho Roadless Rule and associated maps mistakenly identify a Forest Plan Special Area (Wild and Scenic River) along Big Creek. During the Idaho rulemaking, Forest Plan Special Areas were identified where the management is governed by specific Agency directives and forest plan direction. The 2003 Southwest Idaho Ecogroup Land and Resource Management Plan Final Environmental Impact Statement (FEIS) included an eligibility study for Big Creek. However, the Agency’s Record of Decision did not find Big Creek eligible for Wild and Scenic River designation. As the Payette Forest Plan did not establish a special management area, the Idaho rulemaking and associated maps should be conformed to remove this erroneous classification. These proposed corrections occur in T20N, R8E, sections 13–14 and 22–24; T20N, R9E, sections 2–3, 10, 15, and 17–18; T21N, R9E, sections 13, 23–24, 26, and 34–36, Boise Meridian. Summary of Proposed Changes The rule and associated maps will be corrected as follows: • Big Creek Fringe Idaho Roadless Area: Change 365 acres of Forest Plan Special Area to Backcountry/Restoration and deletes 3 acres of private ownership. The FPSA classification will be removed in the rule. • Placer Creek Idaho Roadless Area: Change 98 acres of Forest Plan Special Area to Backcountry/Restoration; and 14 acres of Forest Plan Special Area to Primitive. The FPSA classification will be removed in the rule. • Secesh Idaho Roadless Area: Change 1,086 acres of Forest Plan Special Area to Backcountry/ Restoration. • Smith Creek Roadless Area: Change 14 acres of Forest Plan Special Area to Primitive. Correction Regarding French Creek The Idaho Roadless Rule erroneously did not identify an existing Forest Plan Special area for the Wild and Scenic River corridor along Lake Creek in the French Creek Idaho Roadless Area. The 2003 Southwest Idaho Ecogroup Land and Resource Management Plan Final Environmental Impact Statement included a suitability study for the Secesh River, including Lake Creek. The Record of Decision found the Secesh River, including Lake Creek, eligible for Wild and Scenic River designation and the Payette National Forest Land and Resource Management Plans established a special management area. Therefore, E:\FR\FM\08SEP1.SGM 08SEP1

Agencies

[Federal Register Volume 75, Number 173 (Wednesday, September 8, 2010)]
[Proposed Rules]
[Pages 54541-54542]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-22239]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 31

[REG-146893-02, REG-115037-00]
RIN 1545-BJ32


Treatment of Services Under Section 482; Allocation of Income and 
Deductions From Intangibles

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking.

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

SUMMARY: This document withdraws proposed regulations published in the 
Federal Register on September 10, 2003 (68 FR 53448), related to the 
treatment of controlled services transactions under section 482 and the 
allocation of income from intangibles, in particular with respect to 
contributions by a controlled party to the value of an intangible that 
is owned by another controlled party. The IRS and Treasury Department 
are withdrawing those proposed regulations because they have been 
superseded.

FOR FURTHER INFORMATION CONTACT: Gregory A. Spring (202) 435-5265 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    On September 10, 2003, the Treasury Department and the IRS 
published in the Federal Register (68 FR 53448, REG-146893-02 and REG-
115037-00) proposed regulations relating to the treatment of controlled 
services transactions and the allocation of income from intangible 
property, in particular with respect to contributions by a controlled 
party to the value of intangible property owned by another controlled 
party. On August 4, 2006, the Treasury Department and the IRS published 
in the Federal Register (71 FR 44466, TD 9278, REG-146893-02, REG-
115037-00, and REG-138603-03) temporary regulations relating to the 
treatment of controlled services transactions, the allocation of income 
from intangible property, and stewardship expenses under Treas. Reg. 
Sec.  1.861-8(e)(4). A notice of proposed rulemaking cross-referencing 
the temporary regulations was published in the Federal Register on the 
same day (71 FR 44247). Written comments responding to the notice of 
proposed rulemaking were received, and a public hearing was held on 
October 27, 2006. That notice of proposed rulemaking superseded the 
proposed regulations published in the Federal Register on September 10, 
2003.
    On August 4, 2009, the Treasury Department and the IRS published in 
the Federal Register (74 FR 38830, TD 9456) final regulations that are 
generally consistent with the proposed regulations that were published 
on August 4, 2006, in the Federal Register (71 FR 44247), and removed 
the corresponding temporary regulations.

List of Subjects

26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

26 CFR Part 31

    Employment taxes, Income taxes, Penalties, Pensions, Railroad 
retirement, Reporting and recordkeeping

[[Page 54542]]

requirements, Social Security, Unemployment compensation.

Withdrawal of a Notice of Proposed Rulemaking

    Accordingly, under the authority of 26 U.S.C. 7805, the notice of 
proposed rulemaking (REG-146893-02 and REG-115037-00) published in the 
Federal Register on September 10, 2003 (68 FR 53448) is withdrawn.

Steven T. Miller,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2010-22239 Filed 9-7-10; 8:45 am]
BILLING CODE 4830-01-P
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