Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities, 12867-12878 [2014-03960]

Download as PDF Vol. 79 Thursday, No. 44 March 6, 2014 Part IV Department of the Treasury tkelley on DSK3SPTVN1PROD with PROPOSALS2 Internal Revenue Service 26 CFR Part 1 Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities; Proposed Rule VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\06MRP2.SGM 06MRP2 12868 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules placed on the building access list to attend the hearing, Oluwafunmilayo (Funmi) Taylor, at (202) 317–5179 (not toll-free numbers). SUPPLEMENTARY INFORMATION: DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG–130967–13] RIN 1545–BL72 Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing. AGENCY: In this issue of the Federal Register, the IRS and the Department of the Treasury (Treasury Department) are issuing final and temporary regulations that provide guidance under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code). These regulations address reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities. The text of the temporary regulations published in the Federal Register also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations. DATES: Written and/or electronic comments must be received by May 5, 2014. Outlines of topics to be discussed at the public hearing scheduled for June 24, 2014, at 10 a.m. must be received by May 5, 2014. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG–130967–13), Room 5203, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be handdelivered Monday through Friday between the hours of 8:00 a.m. and 4:00 p.m. to CC:PA:LPD:PR (REG–130967– 13), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, DC 20224, or sent electronically, via the Federal eRulemaking Portal at www.regulations.gov (IRS REG–130967– 13). 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 proposed regulations, Tara Ferris, Nancy Lee, Michael Kaercher, or Kamela Nelan at (202) 317– 6942; concerning submission of comments, the hearing, and/or to be tkelley on DSK3SPTVN1PROD with PROPOSALS2 SUMMARY: VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 Background Temporary regulations in this issue of the Federal Register amend the Income Tax Regulations (26 CFR part 1) under chapter 4 of Subtitle A of the Code. The temporary regulations set forth rules relating to information reporting by FFIs with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities. The temporary regulations revise and refine final regulations (TD 9610) under chapter 4 that were published in the Federal Register (78 FR 5874) on January 28, 2013, as corrected on September 10, 2013 (78 FR 55202). The text of the temporary regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations explains the temporary regulations and these proposed regulations. Special Analyses It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in Executive Order 12866, as supplemented by Executive Order 13653. 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. It is hereby certified that the collection of information in this notice of proposed rulemaking will not have a significant economic impact on a substantial number of small business entities within the meaning of section 601(6) of the Regulatory Flexibility Act (5 U.S.C. chapter 6). Although the Treasury Department and the IRS anticipate that a substantial number of domestic small business entities will be affected by the collection of information in this notice of proposed rulemaking, the Treasury Department and the IRS believe that the economic impact to these entities resulting from the information collection requirements will not be significant. The domestic small business entities that are subject to chapter 4 and the collection of information in this notice of proposed rulemaking are those domestic business entities that are payors of certain U.S. source income that are presently subject to the information collection and reporting rules under chapter 3. These domestic small business entities are required to PO 00000 Frm 00002 Fmt 4701 Sfmt 4702 be familiar with chapter 3’s information collection and reporting rules and forms in order to determine a payee’s U.S. withholding status and, based on that status, withhold and remit the proper amount of tax on payments of U.S. source FDAP income. Small domestic business entities that are payors of U.S. source income have developed and implemented internal reporting and information collection systems under which the business entity satisfies its chapter 3 payee identification, withholding, and tax remittance requirements. The IRS intends to revise the present chapter 3 reporting forms, with the revised forms being used by a payor of U.S. source income to satisfy the payor’s obligations under chapters 3 and 4. As a result, the information collection requirements of this notice of proposed rulemaking build on reporting and information collection systems familiar to and currently used by payors of U.S. source FDAP income that are domestic small business entities. Because the information collection and reporting requirements of chapter 4 and this notice of proposed rulemaking build on existing chapter 3 information collection and reporting systems of domestic small business entities making payments of U.S. source income to foreign persons, the information collection requirements of this notice of proposed rulemaking impose little additional burden on those domestic entities. Therefore, a Regulatory Flexibility Analysis under the Regulatory Flexibility Act is not required. Pursuant to section 7805(f) of the Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small businesses. The IRS invites the public to comment on this certification. Comments and 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. The IRS and the Treasury Department request comments on all aspects of the proposed regulations. All comments will be available for public inspection and copying. A public hearing has been scheduled for June 24, 2014, beginning at 10 a.m. in the Auditorium, Internal Revenue Building, 1111 Constitution Avenue NW., Washington, DC. Due to building security procedures, visitors must enter E:\FR\FM\06MRP2.SGM 06MRP2 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules 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 area 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, an outline of the topics to be discussed, and the time to be devoted to each topic. Submit a signed original and eight (8) copies or an electronic copy of the topics outline by May 5, 2014. A period of 10 minutes 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 authors of these regulations are Tara Ferris, Nancy Lee, Michael Kaercher, and Kamela Nelan of the Office of Associate Chief Counsel (International). However, other personnel from the IRS and the Treasury Department participated in the development of these regulations. 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: tkelley on DSK3SPTVN1PROD with PROPOSALS2 ■ Authority: 26 U.S.C. 7805. * * * Section 1.1471–1 is also issued under 26 U.S.C. 1471. Section 1.1471–2 is also issued under 26 U.S.C. 1471. Section 1.1471–3 is also issued under 26 U.S.C. 1471. Section 1.1471–4 is also issued under 26 U.S.C. 1471. Section 1.1471–5 is also issued under 26 U.S.C. 1471. Section 1.1471–6 is also issued under 26 U.S.C. 1471. Section 1.1472–1 is also issued under 26 U.S.C. 1472. Section 1.1471–3 is also issued under 26 U.S.C. 1473. VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 Section 1.1474–1 is also issued under 26 U.S.C. 1474. Section 1.1474–6 is also issued under 26 U.S.C. 1474. Par. 2. Section 1.1471–1 is amended by: ■ 1. Removing paragraph (b)(81). ■ 2. Redesignating paragraphs (b)(115) through (b)(142) as (b)(124) through (b)(151), paragraphs (b)(108) through (b)(114) as (b)(116) through (b)(122), paragraph (b)(107) as (b)(114), paragraphs (b)(82) through (b)(106) as (b)(88) through (b)(112), paragraphs (b)(75) through (b)(80) as (b)(82) through (b)(87), paragraphs (b)(62) through (b)(74) as (b)(68) through (b)(80), paragraphs (b)(39) through (b)(61) as (b)(44) through (b)(66), paragraphs (b)(28) through (b)(38) as (b)(32) through (b)(42), paragraphs (b)(18) through (b)(27) as (b)(21) through (b)(30), paragraphs (b)(9) through (b)(17) as (b)(11) through (b)(19), and paragraphs (b)(7) and (b)(8) as (b)(8) and (b)(9). ■ 3. Adding new paragraphs (b)(7), (b)(10), (b)(20), (b)(31), (b)(43), (b)(67), (b)(81), (b)(113), (b)(115), and (b)(123). ■ 4. Revising paragraphs (b)(23), (b)(35), (b)(41), (b)(48), (b)(50), (b)(76), (b)(77), (b)(83), (b)(88), (b)(91), (b)(98), (b)(100), (b)(104)(i), (b)(104)(ii)(A) through (C), (b)(105), (b)(124), (b)(125), (b)(128), (b)(135) and (b)(141). The revisions and additions read as follows: ■ § 1.1471–1 Scope of chapter 4 and definitions. * * * * * (b) * * * (7) [The text of proposed § 1.1471– 1(b)(7) is the same as the text of § 1.1471–1T(b)(7) published elsewhere in this issue of the Federal Register]. * * * * * (10) [The text of proposed § 1.1471– 1(b)(10) is the same as the text of § 1.1471–1T(b)(10) published elsewhere in this issue of the Federal Register]. * * * * * (20) [The text of proposed § 1.1471– 1(b)(20) is the same as the text of § 1.1471–1T(b)(20) published elsewhere in this issue of the Federal Register]. * * * * * (23) [The text of the proposed amendment to § 1.1471–1(b)(23) is the same as the text of § 1.1471–1T(b)(23) published elsewhere in this issue of the Federal Register]. * * * * * (31) [The text of proposed § 1.1471– 1(b)(31) is the same as the text of § 1.1471–1T(b)(31) published elsewhere in this issue of the Federal Register]. * * * * * (35) [The text of the proposed amendment to § 1.1471–1(b)(35) is the PO 00000 Frm 00003 Fmt 4701 Sfmt 4702 12869 same as the text of § 1.1471–1T(b)(35) published elsewhere in this issue of the Federal Register]. * * * * * (41) [The text of the proposed amendment to § 1.1471–1(b)(41) is the same as the text of § 1.1471–1T(b)(41) published elsewhere in this issue of the Federal Register]. * * * * * (43) [The text of proposed § 1.1471– 1(b)(43) is the same as the text of § 1.1471–1T(b)(43) published elsewhere in this issue of the Federal Register]. * * * * * (48) [The text of the proposed amendment to § 1.1471–1(b)(48) is the same as the text of § 1.1471–1T(b)(48) published elsewhere in this issue of the Federal Register]. * * * * * (50) [The text of the proposed amendment to § 1.1471–1(b)(50) is the same as the text of § 1.1471–1T(b)(50) published elsewhere in this issue of the Federal Register]. * * * * * (67) [The text of proposed § 1.1471– 1(b)(67) is the same as the text of § 1.1471–1T(b)(67) published elsewhere in this issue of the Federal Register]. * * * * * (76) [The text of the proposed amendment to § 1.1471–1(b)(76) is the same as the text of § 1.1471–1T(b)(76) published elsewhere in this issue of the Federal Register]. (77) [The text of the proposed amendment to § 1.1471–1(b)(77) is the same as the text of § 1.1471–1T(b)(77) published elsewhere in this issue of the Federal Register]. * * * * * (81) [The text of proposed § 1.1471– 1(b)(81) is the same as the text of § 1.1471–1T(b)(81) published elsewhere in this issue of the Federal Register]. * * * * * (83) [The text of the proposed amendment to § 1.1471–1(b)(83) is the same as the text of § 1.1471–1T(b)(83) published elsewhere in this issue of the Federal Register]. * * * * * (88) [The text of the proposed amendment to § 1.1471–1(b)(88) is the same as the text of § 1.1471–1T(b)(88) published elsewhere in this issue of the Federal Register]. * * * * * (91) [The text of the proposed amendment to § 1.1471–1(b)(91) is the same as the text of § 1.1471–1T(b)(91) published elsewhere in this issue of the Federal Register]. * * * * * E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 12870 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules (98) [The text of the proposed amendment to § 1.1471–1(b)(98) is the same as the text of § 1.1471–1T(b)(98) published elsewhere in this issue of the Federal Register]. * * * * * (100) [The text of the proposed amendment to § 1.1471–1(b)(100) is the same as the text of § 1.1471–1T(b)(100) published elsewhere in this issue of the Federal Register]. * * * * * (104) * * * (i) [The text of the proposed amendment to § 1.1471– 1(b)(104)(i) is the same as the text of § 1.1471–1T(b)(104)(i) published elsewhere in this issue of the Federal Register]. (ii) * * * (A) [The text of the proposed amendment to § 1.1471–1(b)(104)(ii)(A) is the same as the text of § 1.1471– 1T(b)(104)(ii)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–1(b)(104)(ii)(B) is the same as the text of § 1.1471– 1T(b)(104)(ii)(B) published elsewhere in this issue of the Federal Register]. (C) [The text of the proposed amendment to § 1.1471–1(b)(104)(ii)(C) is the same as the text of § 1.1471– 1T(b)(104)(ii)(C) published elsewhere in this issue of the Federal Register]. (105) [The text of the proposed amendment to § 1.1471–1(b)(105) is the same as the text of § 1.1471–1T(b)(105) published elsewhere in this issue of the Federal Register]. * * * * * (113) [The text of proposed § 1.1471– 1(b)(113) is the same as the text of § 1.1471–1T(b)(113) published elsewhere in this issue of the Federal Register]. * * * * * (115) [The text of proposed § 1.1471– 1(b)(115) is the same as the text of § 1.1471–1T(b)(115) published elsewhere in this issue of the Federal Register]. * * * * * (123) [The text of proposed § 1.1471– 1(b)(123) is the same as the text of § 1.1471–1T(b)(123) published elsewhere in this issue of the Federal Register]. (124) [The text of the proposed amendment to § 1.1471–1(b)(124) is the same as the text of § 1.1471–1T(b)(124) published elsewhere in this issue of the Federal Register]. (125) [The text of the proposed amendment to § 1.1471–1(b)(125) is the same as the text of § 1.1471–1T(b)(125) published elsewhere in this issue of the Federal Register]. * * * * * VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 (128) [The text of the proposed amendment to § 1.1471–1(b)(128) is the same as the text of § 1.1471–1T(b)(128) published elsewhere in this issue of the Federal Register]. * * * * * (135) [The text of the proposed amendment to § 1.1471–1(b)(135) is the same as the text of § 1.1471–1T(b)(135) published elsewhere in this issue of the Federal Register]. * * * * * (141) [The text of the proposed amendment to § 1.1471–1(b)(141) is the same as the text of § 1.1471–1T(b)(141) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 3. In § 1.1471–2, ■ a. Revise paragraphs (a)(1), (a)(2)(i), (a)(2)(ii) introductory text, (a)(2)(iii)(A), and (a)(2)(v). ■ b. Remove the heading of paragraph (a)(4)(ii), and add introductory text to paragraph (a)(4)(ii). ■ c. Revise paragraphs (a)(4)(ii)(A), (a)(4)(ii)(B), (b)(2)(i)(A)(1), (b)(2)(ii)(A)(4), (b)(2)(ii)(B)(2), (b)(2)(iv), and (b)(4)(ii). The revisions read as follows: § 1.1471–2 Requirement to deduct and withhold tax on withholdable payments to certain FFIs. (a) * * * (1) [The text of the proposed amendment to § 1.1471–2(a)(1) is the same as the text of § 1.1471–2T(a)(1) published elsewhere in this issue of the Federal Register]. (2) * * * (i) [The text of the proposed amendment to § 1.1471–2(a)(2)(i) is the same as the text of § 1.1471–2T(a)(2)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1471–2(a)(2)(ii) introductory text is the same as the text of § 1.1471–2T(a)(2)(ii) published elsewhere in this issue of the Federal Register]. (iii) * * * (A) [The text of the proposed amendment to § 1.1471–2(a)(2)(iii)(A) is the same as the text of § 1.1471– 2T(a)(2)(iii)(A) published elsewhere in this issue of the Federal Register]. * * * * * (v) [The text of the proposed amendment to § 1.1471–2(a)(2)(v) is the same as the text of § 1.1471–2T(a)(2)(v) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (ii) [The text of the proposed amendment to § 1.1471–2(a)(4)(ii) is the PO 00000 Frm 00004 Fmt 4701 Sfmt 4702 same as the text of § 1.1471–2T(a)(4)(ii) published elsewhere in this issue of the Federal Register]. (A) [The text of the proposed amendment to § 1.1471–2(a)(4)(ii)(A) is the same as the text of § 1.1471– 2T(a)(4)(ii)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–2(a)(4)(ii)(B) is the same as the text of § 1.1471– 2T(a)(4)(ii)(B) published elsewhere in this issue of the Federal Register]. * * * * * (b) * * * (2) * * * (i) * * * (A) * * * (1) [The text of the proposed amendment to § 1.1471–2(b)(2)(i)(A)(1) is the same as the text of § 1.1471– 2T(b)(2)(i)(A)(1) published elsewhere in this issue of the Federal Register]. * * * * * (ii) * * * (A) * * * (4) [The text of the proposed amendment to § 1.1471–2(b)(2)(ii)(A)(4) is the same as the text of § 1.1471– 2T(b)(2)(ii)(A)(4) published elsewhere in this issue of the Federal Register]. * * * * * (B) * * * (2) [The text of the proposed amendment to § 1.1471–2(b)(2)(ii)(B)(2) is the same as the text of § 1.1471– 2T(b)(2)(ii)(B)(2) published elsewhere in this issue of the Federal Register]. * * * * * (iv) [The text of the proposed amendment to § 1.1471–2(b)(2)(iv) is the same as the text of § 1.1471–2T(b)(2)(iv) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (ii) [The text of the proposed amendment to § 1.1471–2(b)(4)(ii) is the same as the text of § 1.1471–2T(b)(4)(ii) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 4. Section 1.1471–3 is amended by: ■ 1. By adding paragraphs (c)(6)(ii)(B)(7), (c)(8)(v), (d)(5)(iii), and (d)(11)(x) through (xii). ■ 2. By revising paragraphs (a)(3)(iii), (a)(3)(v) through (vi), (b)(3), (c)(3)(ii)(C) through (D), (c)(3)(iii)(A) introductory text, (c)(3)(iii)(A)(5), (c)(3)(iii)(B)(1) through (4), (c)(5)(ii)(B), (c)(6)(ii)(B)(3), (c)(6)(ii)(B)(5) through (6), (c)(6)(ii)(C)(3) through (5), (c)(6)(ii)(E)(3), (c)(6)(iv), (c)(6)(v)(A) through (B), (c)(9)(ii)(B), (c)(9)(v), (d)(1), (d)(2)(i), (d)(2)(iii), (d)(4)(i) and (ii), (d)(4)(iii) introductory E:\FR\FM\06MRP2.SGM 06MRP2 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules text, (d)(4)(iii)(A)(1), (d)(4)(iv)(A), (d)(4)(iv)(C) through (D), (d)(4)(v), (d)(5)(i) through (ii), (d)(6)(vii)(A)(1), (d)(11)(viii)(A) introductory text, (d)(11)(viii)(C), (d)(12)(iii)(A) through (B), (e)(2) through (3), (e)(4) introductory text, (e)(4)(i) through (iv), (e)(4)(v) introductory text, (e)(4)(v)(B)(1) through (2), (e)(4)(vi)(B), (e)(4)(vii)(B), (e)(4)(viii)(A)(4), and (f)(1) through (9). The revisions and additions read as follows: tkelley on DSK3SPTVN1PROD with PROPOSALS2 § 1.1471–3 Identification of payee. (a) * * * (3) * * * (iii) [The text of the proposed amendment to § 1.1471–3(a)(3)(iii) is the same as the text of § 1.1471–3T(a)(3)(iii) published elsewhere in this issue of the Federal Register]. * * * * * (v) [The text of the proposed amendment to § 1.1471–3(a)(3)(v) is the same as the text of § 1.1471–3T(a)(3)(v) published elsewhere in this issue of the Federal Register]. (vi) [The text of the proposed amendment to § 1.1471–3(a)(3)(vi) is the same as the text of § 1.1471–3T(a)(3)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (b) * * * (3) [The text of the proposed amendment to § 1.1471–3(b)(3) is the same as the text of § 1.1471–3T(b)(3) published elsewhere in this issue of the Federal Register]. * * * * * (c) * * * (3) * * * (ii) * * * (C) [The text of the proposed amendment to § 1.1471–3(c)(3)(ii)(C) is the same as the text of § 1.1471– 3T(c)(3)(ii)(C) published elsewhere in this issue of the Federal Register]. (D) [The text of the proposed amendment to § 1.1471–3(c)(3)(ii)(D) is the same as the text of § 1.1471– 3T(c)(3)(ii)(D) published elsewhere in this issue of the Federal Register]. * * * * * (iii) * * * (A) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(A) introductory text is the same as the text of § 1.1471–3T(c)(3)(iii)(A) published elsewhere in this issue of the Federal Register]. * * * * * (5) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(A)(5) is the same as the text of § 1.1471– 3T(c)(3)(iii)(A)(5) published elsewhere in this issue of the Federal Register]. * * * * * VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 (B) * * * (1) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(B)(1) is the same as the text of § 1.1471– 3T(c)(3)(iii)(B)(1) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(B)(2) is the same as the text of § 1.1471– 3T(c)(3)(iii)(B)(2) published elsewhere in this issue of the Federal Register]. (3) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(B)(3) is the same as the text of § 1.1471– 3T(c)(3)(iii)(B)(3) published elsewhere in this issue of the Federal Register]. (4) [The text of the proposed amendment to § 1.1471–3(c)(3)(iii)(B)(4) is the same as the text of § 1.1471– 3T(c)(3)(iii)(B)(4) published elsewhere in this issue of the Federal Register]. * * * * * (5) * * * (ii) * * * (B) [The text of the proposed amendment to § 1.1471–3(c)(5)(ii)(B) is the same as the text of § 1.1471– 3T(c)(5)(ii)(B) published elsewhere in this issue of the Federal Register]. * * * * * (6) * * * (ii) * * * (B) * * * (3) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(B)(3) is the same as the text of § 1.1471– 3T(c)(6)(ii)(B)(3) published elsewhere in this issue of the Federal Register]. * * * * * (5) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(B)(5) is the same as the text of § 1.1471– 3T(c)(6)(ii)(B)(5) published elsewhere in this issue of the Federal Register]. (6) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(B)(6) is the same as the text of § 1.1471– 3T(c)(6)(ii)(B)(6) published elsewhere in this issue of the Federal Register]. (7) [The text of proposed § 1.1471– 3(c)(6)(ii)(B)(7) is the same as the text of § 1.1471–3T(c)(6)(ii)(B)(7) published elsewhere in this issue of the Federal Register]. (C) * * * (3) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(C)(3) is the same as the text of § 1.1471– 3T(c)(6)(ii)(C)(3) published elsewhere in this issue of the Federal Register]. (4) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(C)(4) is the same as the text of § 1.1471– 3T(c)(6)(ii)(C)(4) published elsewhere in this issue of the Federal Register]. (5) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(C)(5) is the same as the text of § 1.1471– PO 00000 Frm 00005 Fmt 4701 Sfmt 4702 12871 3T(c)(6)(ii)(C)(5) published elsewhere in this issue of the Federal Register]. * * * * * (E) * * * (3) [The text of the proposed amendment to § 1.1471–3(c)(6)(ii)(E)(3) is the same as the text of § 1.1471– 3T(c)(6)(ii)(E)(3) published elsewhere in this issue of the Federal Register]. * * * * * (iv) [The text of the proposed amendment to § 1.1471–3(c)(6)(iv) is the same as the text of § 1.1471–3T(c)(6)(iv) published elsewhere in this issue of the Federal Register]. (v) * * * (A) [The text of the proposed amendment to § 1.1471–3(c)(6)(v)(A) is the same as the text of § 1.1471– 3T(c)(6)(v)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–3(c)(6)(v)(B) is the same as the text of § 1.1471– 3T(c)(6)(v)(B) published elsewhere in this issue of the Federal Register]. * * * * * (8) * * * (v) [The text of proposed § 1.1471– 3(c)(8)(v) is the same as the text of § 1.1471–3T(c)(8)(v) published elsewhere in this issue of the Federal Register]. (9) * * * (ii) * * * (B) [The text of the proposed amendment to § 1.1471–3(c)(9)(ii)(B) is the same as the text of § 1.1471– 3T(c)(9)(ii)(B) published elsewhere in this issue of the Federal Register]. * * * * * (v) [The text of the proposed amendment to § 1.1471–3(c)(9)(v) is the same as the text of § 1.1471–3T(c)(9)(v) published elsewhere in this issue of the Federal Register]. (d) * * * (1) [The text of the proposed amendment to § 1.1471–3(d)(1) is the same as the text of § 1.1471–3T(d)(1) published elsewhere in this issue of the Federal Register]. (2) * * * (i) [The text of the proposed amendment to § 1.1471–3(d)(2)(i) is the same as the text of § 1.1471–3T(d)(2)(i) published elsewhere in this issue of the Federal Register]. * * * * * (iii) [The text of the proposed amendment to § 1.1471–3(d)(2)(iii) is the same as the text of § 1.1471– 3T(d)(2)(iii) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (i) [The text of the proposed amendment to § 1.1471–3(d)(4)(i) is the E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 12872 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules same as the text of § 1.1471–3T(d)(4)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1471–3(d)(4)(ii) is the same as the text of § 1.1471–3T(d)(4)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of the proposed amendment to § 1.1471–3(d)(4)(iii) introductory text is the same as the text of § 1.1471–3T(d)(4)(iii) published elsewhere in this issue of the Federal Register]. (A) * * * (1) [The text of the proposed amendment to § 1.1471–3(d)(4)(iii)(A)(1) is the same as the text of § 1.1471– 3T(d)(4)(iii)(A)(1) published elsewhere in this issue of the Federal Register]. * * * * * (iv) * * * (A) [The text of the proposed amendment to § 1.1471–3(d)(4)(iv)(A) is the same as the text of § 1.1471– 3T(d)(4)(iv)(A) published elsewhere in this issue of the Federal Register]. * * * * * (C) [The text of the proposed amendment to § 1.1471–3(d)(4)(iv)(C) is the same as the text of § 1.1471– 3T(d)(4)(iv)(C) published elsewhere in this issue of the Federal Register]. (D) [The text of the proposed amendment to § 1.1471–3(d)(4)(iv)(D) is the same as the text of § 1.1471– 3T(d)(4)(iv)(D) published elsewhere in this issue of the Federal Register]. (v) [The text of the proposed amendment to § 1.1471–3(d)(4)(v) is the same as the text of § 1.1471–3T(d)(4)(v) published elsewhere in this issue of the Federal Register]. (5) * * * (i) [The text of the proposed amendment to § 1.1471–3(d)(5)(i) is the same as the text of § 1.1471–3T(d)(5)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1471–3(d)(5)(ii) is the same as the text of § 1.1471– 3T(d)(5)(ii)(A) published elsewhere in this issue of the Federal Register]. (iii) [The text of proposed § 1.1471– 3(d)(5)(iii) is the same as the text of § 1.1471–3T(d)(5)(iii) published elsewhere in this issue of the Federal Register]. (6) * * * (vii) * * * (A) * * * (1) [The text of the proposed amendment to § 1.1471– 3(d)(6)(vii)(A)(1) is the same as the text of § 1.1471–3T(d)(6)(vii)(A)(1) published elsewhere in this issue of the Federal Register]. * * * * * VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 (11) * * * (viii) * * * (A) [The text of the proposed amendment to § 1.1471–3(d)(11)(viii)(A) introductory text is the same as the text of § 1.1471–3T(d)(11)(viii)(A) published elsewhere in this issue of the Federal Register]. * * * * * (C) [The text of the proposed amendment to § 1.1471–3(d)(11)(viii)(C) is the same as the text of § 1.1471– 3T(d)(11)(vii)(C) published elsewhere in this issue of the Federal Register]. * * * * * (x) [The text of proposed § 1.1471– 3(d)(11)(x) is the same as the text of § 1.1471–3T(d)(11)(x) published elsewhere in this issue of the Federal Register]. (xi) [The text of proposed § 1.1471– 3(d)(11)(xi) is the same as the text of § 1.1471–3T(d)(11)(xi) published elsewhere in this issue of the Federal Register]. (xii) [The text of proposed § 1.1471– 3(d)(11)(xii) is the same as the text of § 1.1471–3T(d)(11)(xii) published elsewhere in this issue of the Federal Register]. (12) * * * (iii) * * * (A) [The text of the proposed amendment to § 1.1471–3(d)(12)(iii)(A) is the same as the text of § 1.1471– 3T(d)(12)(iii)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–3(d)(12)(iii)(B) is the same as the text of § 1.1471– 3T(d)(12)(iii)(B) published elsewhere in this issue of the Federal Register]. (e) * * * (2) [The text of the proposed amendment to § 1.1471–3(e)(2) is the same as the text of § 1.1471–3T(e)(2) published elsewhere in this issue of the Federal Register]. (3) [The text of proposed § 1.1471– 3(e)(3) is the same as the text of § 1.1471–3T(e)(3) through (e)(3)(iv) published elsewhere in this issue of the Federal Register]. (4) [The text of the proposed amendment to § 1.1471–3(e)(4) introductory text is the same as the text of § 1.1471–3T(e)(4) introductory text published elsewhere in this issue of the Federal Register]. (i) through (iv) [The text of the proposed amendment to § 1.1471– 3(e)(4)(i) through (iv) is the same as the text of § 1.1471–3T(e)(4)(i) through (iv)(B)(2) published elsewhere in this issue of the Federal Register]. (v) [The text of the proposed amendment to § 1.1471–3(e)(4)(v) introductory text is the same as the text PO 00000 Frm 00006 Fmt 4701 Sfmt 4702 of § 1.1471–3T(e)(4)(v) published elsewhere in this issue of the Federal Register]. * * * * * (B) * * * (1) [The text of the proposed amendment to § 1.1471–3(e)(4)(v)(B)(1) is the same as the text of § 1.1471– 3T(e)(4)(v)(B)(1) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1471–3(e)(4)(v)(B)(2) is the same as the text of § 1.1471– 3T(e)(4)(v)(B)(2) published elsewhere in this issue of the Federal Register]. * * * * * (vi) * * * (B) [The text of the proposed amendment to § 1.1471–3(e)(4)(vi)(B) is the same as the text of § 1.1471– 3T(e)(4)(vi)(B) published elsewhere in this issue of the Federal Register]. (vii) * * * (B) [The text of the proposed amendment to § 1.1471–3(e)(4)(vii)(B) is the same as the text of § 1.1471– 3T(e)(4)(vii)(B) published elsewhere in this issue of the Federal Register]. (viii) * * * (A) * * * (4) [The text of the proposed amendment to § 1.1471– 3(e)(4)(viii)(A)(4) is the same as the text of § 1.1471–3T(e)(4)(viii)(A)(4) published elsewhere in this issue of the Federal Register]. * * * * * (f) * * * (1) through (9) [The text of the proposed amendment to § 1.1471–3(f)(1) through (9) is the same as the text of § 1.1471–3T(f)(1) through (f)(9)(ii) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 5. Section 1.1471–4 is amended by: ■ 1. Removing paragraph (d)(3)(v). ■ 2. Redesignating paragraphs (d)(3)(vi) through (viii) as paragraphs (d)(3)(v) through (vii) and paragraph (d)(6)(vi) as paragraph (d)(6)(vii). ■ 3. Adding paragraphs (b)(3)(i) through (iii), (d)(2)(ii)(F), (d)(2)(iii)(C), and (d)(6)(vi). ■ 4. Revising paragraphs (a)(3), (b)(1) through (3), (b)(6), (c)(5)(iv)(B)(2)(vi), (c)(5)(iv)(E), (d)(1), (d)(2)(i), (d)(2)(ii)(A), (d)(2)(ii)(B)(2), (d)(2)(ii)(E), (d)(2)(iii)(A), (d)(2)(iii)(B) introductory text, (d)(3)(ii)(E), (d)(3)(iii)(F), (d)(5)(v) through (vi), (d)(7)(i), (d)(7)(ii)(A), (d)(7)(iii), (d)(7)(iv)(A) through (B), (d)(8), (d)(9) Example 3, Example 5, and Example 7, (e)(1), (e)(2)(ii), (f)(4)(i) through (ii), (g)(1) introductory text, (g)(1)(ii), and (g)(2). E:\FR\FM\06MRP2.SGM 06MRP2 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules 5. By removing the heading of paragraph (d)(7) and adding introductory text to paragraph (d)(7). The additions and revisions read as follows: ■ tkelley on DSK3SPTVN1PROD with PROPOSALS2 § 1.1471–4 FFI agreement. (a) * * * (3) [The text of the proposed amendment to § 1.1471–4(a)(3) is the same as the text of § 1.1471–4T(a)(3) published elsewhere in this issue of the Federal Register]. * * * * * (b) * * * (1) [The text of the proposed amendment to § 1.1471–4(b)(1) is the same as the text of § 1.1471–4T(b)(1) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1471–4(b)(2) is the same as the text of § 1.1471–4T(b)(2) published elsewhere in this issue of the Federal Register]. (3) [The text of the proposed amendment to § 1.1471–4(b)(3) is the same as the text of § 1.1471–4T(b)(3) published elsewhere in this issue of the Federal Register]. (i) [The text of proposed § 1.1471– 4(b)(3)(i) is the same as the text of § 1.1471–4T(b)(3)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of proposed § 1.1471– 4(b)(3)(ii) is the same as the text of § 1.1471–4T(b)(3)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of proposed § 1.1471– 4(b)(3)(iii) is the same as the text of § 1.1471–4T(b)(3)(iii) published elsewhere in this issue of the Federal Register]. * * * * * (6) [The text of the proposed amendment to § 1.1471–4(b)(6) is the same as the text of § 1.1471–4T(b)(6) published elsewhere in this issue of the Federal Register]. * * * * * (c) * * * (5) * * * (iv) * * * (B) * * * (2) * * * (vi) [The text of the proposed amendment to § 1.1471– 4(c)(5)(iv)(B)(2)(vi) is the same as the text of § 1.1471–4T(c)(5)(iv)(B)(2)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (E) [The text of the proposed amendment to § 1.1471–4(c)(5)(iv)(E) is the same as the text of § 1.1471– VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 4T(c)(5)(iv)(E) published elsewhere in this issue of the Federal Register]. * * * * * (d) * * * (1) [The text of the proposed amendment to § 1.1471–4(d)(1) is the same as the text of § 1.1471–4T(d)(1) published elsewhere in this issue of the Federal Register]. (2) * * * (i) [The text of the proposed amendment to § 1.1471–4(d)(2)(i) is the same as the text of § 1.1471–4T(d)(2)(i) published elsewhere in this issue of the Federal Register]. (ii) * * * (A) [The text of the proposed amendment to § 1.1471–4(d)(2)(ii)(A) is the same as the text of § 1.1471– 4T(d)(2)(ii)(A) published elsewhere in this issue of the Federal Register]. (B) * * * (2) [The text of the proposed amendment to § 1.1471–4(d)(2)(ii)(B)(2) is the same as the text of § 1.1471– 4T(d)(2)(ii)(B)(2) published elsewhere in this issue of the Federal Register]. * * * * * (E) [The text of the proposed amendment to § 1.1471–4(d)(2)(ii)(E) is the same as the text of § 1.1471– 4T(d)(2)(ii)(E) published elsewhere in this issue of the Federal Register]. (F) [The text of proposed § 1.1471– 4(d)(2)(ii)(F) is the same as the text of § 1.1471–4T(d)(2)(ii)(F) published elsewhere in this issue of the Federal Register]. (iii) * * * (A) [The text of the proposed amendment to § 1.1471–4(d)(2)(iii)(A) is the same as the text of § 1.1471– 4T(d)(2)(iii)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–4(d)(2)(iii)(B) introductory text is the same as the text of § 1.1471–4T(d)(2)(iii)(B) published elsewhere in this issue of the Federal Register]. * * * * * (C) [The text of proposed § 1.1471– 4(d)(2)(iii)(C) is the same as the text of § 1.1471–4T(d)(2)(iii)(C) published elsewhere in this issue of the Federal Register]. (3) * * * (ii) * * * (E) [The text of the proposed amendment to § 1.1471–4(d)(3)(ii)(E) is the same as the text of § 1.1471– 4T(d)(3)(ii)(E) published elsewhere in this issue of the Federal Register]. (iii) * * * (F) [The text of the proposed amendment to § 1.1471–4(d)(3)(iii)(F) is the same as the text of § 1.1471– PO 00000 Frm 00007 Fmt 4701 Sfmt 4702 12873 4T(d)(3)(iii)(F) published elsewhere in this issue of the Federal Register]. * * * * * (5) * * * (v) [The text of the proposed amendment to § 1.1471–4(d)(5)(v) is the same as the text of § 1.1471–4T(d)(5)(v) published elsewhere in this issue of the Federal Register]. (vi) [The text of the proposed amendment to § 1.1471–4(d)(5)(vi) is the same as the text of § 1.1471–4T(d)(5)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (6) * * * (vi) [The text of proposed § 1.1471– 4(d)(6)(vi) is the same as the text of § 1.1471–4T(d)(6)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (7) [The text of the proposed amendment to § 1.1471–4(d)(7) introductory text is the same as the text of § 1.1471–4T(d)(7) introductory text published elsewhere in this issue of the Federal Register]. (i) [The text of the proposed amendment to § 1.1471–4(d)(7)(i) is the same as the text of § 1.1471–4T(d)(7)(i) published elsewhere in this issue of the Federal Register]. (ii) * * * (A) [The text of the proposed amendment to § 1.1471–4(d)(7)(ii)(A) is the same as the text of § 1.1471– 4T(d)(7)(ii)(A) published elsewhere in this issue of the Federal Register]. * * * * * (iii) [The text of the proposed amendment to § 1.1471–4(d)(7)(iii) is the same as the text of § 1.1471– 4T(d)(7)(iii) published elsewhere in this issue of the Federal Register]. (iv) * * * (A) [The text of the proposed amendment to § 1.1471–4(d)(7)(iv)(A) is the same as the text of § 1.1471– 4T(d)(7)(iv)(A) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–4(d)(7)(iv)(B) is the same as the text of § 1.1471– 4T(d)(7)(iv)(B) published elsewhere in this issue of the Federal Register]. (8) [The text of the proposed amendment to § 1.1471–4(d)(8) is the same as the text of § 1.1471–4T(d)(8) published elsewhere in this issue of the Federal Register]. (9) * * * Example 3. [The text of the proposed amendment to Example 3 of § 1.1471– 4(d)(9) is the same as the text of Example 3 of § 1.1471–4T(d)(9) published elsewhere in this issue of the Federal Register]. * * * * * E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 12874 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules Example 5. [The text of the proposed amendment to Example 5 of § 1.1471– 4(d)(9) is the same as the text of Example 5 of § 1.1471–4T(d)(9) published elsewhere in this issue of the Federal Register]. * * * * * Example 7. [The text of the proposed amendment to Example 7 of § 1.1471– 4(d)(9) is the same as the text of Example 7 of § 1.1471–4T(d)(9) published elsewhere in this issue of the Federal Register]. (e) * * * (1) [The text of the proposed amendment to § 1.1471–4(e)(1) is the same as the text of § 1.1471–4T(e)(1) published elsewhere in this issue of the Federal Register]. (2) * * * (ii) [The text of the proposed amendment to § 1.1471–4(e)(2)(ii) is the same as the text of § 1.1471–4T(e)(2)(ii) published elsewhere in this issue of the Federal Register]. * * * * * (f) * * * (4) * * * (i) [The text of the proposed amendment to § 1.1471–4(f)(4)(i) is the same as the text of § 1.1471–4T(f)(4)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1471–4(f)(4)(ii) is the same as the text of § 1.1471–4T(f)(4)(ii) published elsewhere in this issue of the Federal Register]. (g) * * * (1) [The text of the proposed amendment to § 1.1471–4(g)(1) introductory text is the same as the text of § 1.1471–4T(g)(1) introductory text published elsewhere in this issue of the Federal Register]. * * * * * (ii) [The text of the proposed amendment to § 1.1471–4(g)(1)(ii) is the same as the text of § 1.1471–4T(g)(1)(ii) published elsewhere in this issue of the Federal Register]. * * * * * (2) [The text of the proposed amendment to § 1.1471–4(g)(2) is the same as the text of § 1.1471–4T(g)(2) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 6. Section 1.1471–5 is amended by: ■ 1. By removing paragraphs (a)(3)(ii) (b)(3)(v)(B)(3), and (b)(3)(vi)(B)(3). ■ 2. By redesignating paragraphs (a)(3)(iii) through (a)(3)(vi) as paragraphs (a)(3)(ii) through (a)(3)(v) and paragraph (j) as paragraph (l). ■ 3. By adding paragraphs (f)(1)(i)(F)(3)(vii), (f)(1)(i)(F)(3)(viii), (f)(2)(v), (j), and (k). VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 4. By revising paragraphs (a)(3)(i), (a)(4)(i), (b)(1)(iii)(B)(2), (b)(3)(iv), (b)(3)(v)(A), (b)(3)(v)(B)(1) through (2), (b)(3)(vi), (c), (e)(1)(v)(A), (e)(3)(ii), (e)(4)(v) Example 7 through Example 8, (e)(5)(i)(A)(3), (e)(5)(i)(B) introductory text, (e)(5)(i)(B)(1), (e)(5)(i)(C), (e)(5)(i)(D)(1)(iv) through (v), (e)(5)(iv)(B), (f)(1)(i)(A)(6), (f)(1)(i)(B)(1), (f)(1)(i)(B)(3), (f)(1)(i)(C)(2), (f)(1)(i)(D)(4) through (6), (f)(1)(i)(D)(7) introductory text, (f)(1)(i)(E), (f)(1)(i)(F)(1)(ii), (f)(1)(i)(F)(3)(v) through (vi), (f)(1)(i)(F)(5), (f)(1)(ii)(B), (f)(2) introductory text, (f)(2)(i)(B), (f)(2)(iii) through (iv), (f)(4)(i), (g)(3)(i)(D), and (i). The additions and revisions read as follows: ■ § 1.1471–5 Definitions applicable to section 1471. (a) * * * (3) * * * (i) [The text of the proposed amendment to § 1.1471–5(a)(3)(i) is the same as the text of § 1.1471–5T(a)(3)(i) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (i) [The text of the proposed amendment to § 1.1471–5(a)(4)(i) is the same as the text of § 1.1471–5T(a)(4)(i) published elsewhere in this issue of the Federal Register]. * * * * * (b) * * * (1) * * * (iii) * * * (B) * * * (2) [The text of the proposed amendment to § 1.1471–5(b)(1)(iii)(B)(2) is the same as the text of § 1.1471– 5T(b)(1)(iii)(B)(2) published elsewhere in this issue of the Federal Register]. * * * * * (3) * * * (iv) [The text of the proposed amendment to § 1.1471–5(b)(3)(iv) is the same as the text of § 1.1471–5T(b)(3)(iv) published elsewhere in this issue of the Federal Register]. (v) * * * (A) [The text of the proposed amendment to § 1.1471–5(b)(3)(v)(A) is the same as the text of § 1.1471– 5T(b)(3)(v)(A) published elsewhere in this issue of the Federal Register]. (B) * * * (1) [The text of the proposed amendment to § 1.1471–5(b)(3)(v)(B)(1) is the same as the text of § 1.1471– 5T(b)(3)(v)(B)(1) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1471–5(b)(3)(v)(B)(2) is the same as the text of § 1.1471– 5T(b)(3)(v)(B)(2) published elsewhere in this issue of the Federal Register]. PO 00000 Frm 00008 Fmt 4701 Sfmt 4702 (vi) [The text of the proposed amendment to § 1.1471–5(b)(3)(vi) is the same as the text of § 1.1471–5T(b)(3)(vi) through (b)(3)(vi)(B)(2) published elsewhere in this issue of the Federal Register]. * * * * * (c) [The text of the proposed amendment to § 1.1471–5(c) is the same as the text of § 1.1471–5T(c) published elsewhere in this issue of the Federal Register]. * * * * * (e) * * * (1) * * * (v) * * * (A) [The text of the proposed amendment to § 1.1471–5(e)(1)(v)(A) is the same as the text of § 1.1471– 5T(e)(1)(v)(A) published elsewhere in this issue of the Federal Register]. * * * * * (3) * * * (ii) [The text of the proposed amendment to § 1.1471–5(e)(3)(ii) is the same as the text of § 1.1471–5T(e)(3)(ii) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (v) * * * Example 7. [The text of the proposed amendment to Example 7of § 1.1471– 5(e)(4)(v) is the same as the text of Example 7 of § 1.1471–5T(e)(4)(v) published elsewhere in this issue of the Federal Register]. Example 8. [The text of the proposed amendment to Example 8 of § 1.1471– 5(e)(4)(v) is the same as the text of Example 8 of § 1.1471–5T(e)(4)(v) published elsewhere in this issue of the Federal Register]. * * * * * (5) * * * (i) * * * (A) * * * (3) [The text of the proposed amendment to § 1.1471–5(e)(5)(i)(A)(3) is the same as the text of § 1.1471– 5T(e)(5)(i)(A)(3) published elsewhere in this issue of the Federal Register]. (B) [The text of the proposed amendment to § 1.1471–5(e)(5)(i)(B) introductory text is the same as the text of § 1.1471–5T(e)(5)(i)(B) published elsewhere in this issue of the Federal Register]. (1) [The text of the proposed amendment to § 1.1471–5(e)(5)(i)(B)(1) is the same as the text of § 1.1471– 5T(e)(5)(i)(B)(1) published elsewhere in this issue of the Federal Register]. * * * * * (C) [The text of the proposed amendment to § 1.1471–5(e)(5)(i)(C) is the same as the text of § 1.1471– E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules 5T(e)(5)(i)(C) published elsewhere in this issue of the Federal Register]. (D) * * * (1) * * * (iv) [The text of the proposed amendment to § 1.1471– 5(e)(5)(i)(D)(1)(iv) is the same as the text of § 1.1471–5T(e)(5)(i)(D)(1)(iv) published elsewhere in this issue of the Federal Register]. (v) [The text of the proposed amendment to § 1.1471– 5(e)(5)(i)(D)(1)(v) is the same as the text of § 1.1471–5T(e)(5)(i)(D)(1)(v) published elsewhere in this issue of the Federal Register]. * * * * * (iv) * * * (B) [The text of the proposed amendment to § 1.1471–5(e)(5)(iv)(B) is the same as the text of § 1.1471– 5T(e)(5)(iv)(B) published elsewhere in this issue of the Federal Register]. * * * * * (f) * * * (1) * * * (i) * * * (A) * * * (6) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(A)(6) is the same as the text of § 1.1471– 5T(f)(1)(i)(A)(6) published elsewhere in this issue of the Federal Register]. * * * * * (B) * * * (1) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(B)(1) is the same as the text of § 1.1471– 5T(f)(1)(i)(B)(1) published elsewhere in this issue of the Federal Register]. * * * * * (3) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(B)(3) is the same as the text of § 1.1471– 5T(f)(1)(i)(B)(3) published elsewhere in this issue of the Federal Register]. (C) * * * (2) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(C)(2) is the same as the text of § 1.1471– 5T(f)(1)(i)(C)(2) published elsewhere in this issue of the Federal Register]. * * * * * (D) * * * (4) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(D)(4) is the same as the text of § 1.1471– 5T(f)(1)(i)(D)(4) published elsewhere in this issue of the Federal Register]. (5) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(D)(5) is the same as the text of § 1.1471– 5T(f)(1)(i)(D)(5) published elsewhere in this issue of the Federal Register]. (6) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(D)(6) is the same as the text of § 1.1471– 5T(f)(1)(i)(D)(6) published elsewhere in this issue of the Federal Register]. VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 (7) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(D)(7) introductory text is the same as the text of § 1.1471–5T(f)(1)(i)(D)(7) introductory text published elsewhere in this issue of the Federal Register]. * * * * * (E) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(E) is the same as the text of § 1.1471– 5T(f)(1)(i)(E) through (f)(1)(i)(E)(2) published elsewhere in this issue of the Federal Register]. (F) * * * (1) * * * (ii) [The text of the proposed amendment to § 1.1471– 5(f)(1)(i)(F)(1)(ii) is the same as the text of § 1.1471–5T(f)(1)(i)(E)(1)(ii) published elsewhere in this issue of the Federal Register]. * * * * * (3) * * * (v) [The text of the proposed amendment to § 1.1471– 5(f)(1)(i)(F)(3)(v) is the same as the text of § 1.1471–5T(f)(1)(i)(F)(3)(v) published elsewhere in this issue of the Federal Register]. (vi) [The text of proposed § 1.1471– 5(f)(1)(i)(F)(3)(vi) is the same as the text of § 1.1471–5T(f)(1)(i)(F)(3)(vi) published elsewhere in this issue of the Federal Register]. (vii) [The text of proposed § 1.1471– 5(f)(1)(i)(F)(3)(vii) is the same as the text of § 1.1471–5T(f)(1)(i)(F)(3)(vii) published elsewhere in this issue of the Federal Register]. (viii) [The text of proposed § 1.1471– 5(f)(1)(i)(F)(3)(viii) is the same as the text of § 1.1471–5T(f)(1)(i)(F)(3)(viii) published elsewhere in this issue of the Federal Register]. * * * * * (5) [The text of the proposed amendment to § 1.1471–5(f)(1)(i)(F)(5) is the same as the text of § 1.1471– 5T(f)(1)(i)(F)(5) published elsewhere in this issue of the Federal Register]. (ii) * * * (B) [The text of the proposed amendment to § 1.1471–5(f)(1)(ii)(B) is the same as the text of § 1.1471– 5T(f)(1)(ii)(B) published elsewhere in this issue of the Federal Register]. * * * * * (2) [The text of the proposed amendment to § 1.1471–5(f)(2) introductory text is the same as the text of § 1.1471–5T(f)(2) published elsewhere in this issue of the Federal Register]. (i) * * * (B) [The text of the proposed amendment to § 1.1471–5(f)(2)(i)(B) is the same as the text of § 1.1471– PO 00000 Frm 00009 Fmt 4701 Sfmt 4702 12875 5T(f)(2)(i)(B) published elsewhere in this issue of the Federal Register]. * * * * * (iii) [The text of the proposed amendment to § 1.1471–5(f)(2)(iii) is the same as the text of § 1.1471–5T(f)(2)(iii) through (f)(2)(iii)(E) published elsewhere in this issue of the Federal Register]. (iv) [The text of the proposed amendment to § 1.1471–5(f)(2)(iv) is the same as the text of § 1.1471–5T(f)(2)(iv) through (f)(2)(iv)(F) published elsewhere in this issue of the Federal Register]. (v) [The text of proposed § 1.1471– 5(f)(2)(v) is the same as the text of § 1.1471–5T(f)(2)(v) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (i) [The text of the proposed amendment to § 1.1471–5(f)(4)(i) is the same as the text of § 1.1471–5T(f)(4)(i) published elsewhere in this issue of the Federal Register]. * * * * * (g) * * * (3) * * * (i) * * * (D) [The text of the proposed amendment to § 1.1471–5(g)(3)(i)(D) is the same as the text of § 1.1471– 5T(g)(3)(i)(D) published elsewhere in this issue of the Federal Register]. * * * * * (i) [The text of proposed § 1.1471–5(i) is the same as the text of § 1.1471–5T(i) through (i)(10) published elsewhere in this issue of the Federal Register]. (j) [The text of proposed § 1.1471–5(j) is the same as the text of § 1.1471–5T(j) published elsewhere in this issue of the Federal Register]. (k) [The text of proposed § 1.1471– 5(k) is the same as the text of § 1.1471– 5T(k) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 7. Section 1.1471–6 is amending by revising paragraphs (d)(1), (d)(4), (f)(2)(iii)(B) through (C), (f)(3)(ii) through (iii), (f)(5) through (6), (g), and (h)(2) to read as follows: § 1.1471–6 Payments beneficially owned by exempt beneficial owners. * * * * * (d) * * * (1) [The text of the proposed amendment to § 1.1471–6(d)(1) is the same as the text of § 1.1471–6T(d)(1) published elsewhere in this issue of the Federal Register]. * * * * * (4) [The text of the proposed amendment to § 1.1471–6(d)(4) is the E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 12876 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules same as the text of § 1.1471–6T(d)(4) published elsewhere in this issue of the Federal Register]. * * * * * (f) * * * (2) * * * (iii) * * * (B) [The text of the proposed amendment to § 1.1471–6(f)(2)(iii)(B) is the same as the text of § 1.1471– 6T(f)(2)(iii)(B) published elsewhere in this issue of the Federal Register]. (C) [The text of the proposed amendment to § 1.1471–6(f)(2)(iii)(C) is the same as the text of § 1.1471– 6T(f)(2)(iii)(C) published elsewhere in this issue of the Federal Register]. * * * * * (3) * * * (ii) [The text of the proposed amendment to § 1.1471–6(f)(3)(ii) is the same as the text of § 1.1471–6T(f)(3)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of the proposed amendment to § 1.1471–6(f)(3)(iii) is the same as the text of § 1.1471–6T(f)(3)(iii) published elsewhere in this issue of the Federal Register]. * * * * * (5) [The text of the proposed amendment to § 1.1471–6(f)(5) is the same as the text of § 1.1471–6T(f)(5) published elsewhere in this issue of the Federal Register]. (6) [The text of the proposed amendment to § 1.1471–6(f)(6) is the same as the text of § 1.1471–6T(f)(6) published elsewhere in this issue of the Federal Register]. * * * * * (g) [The text of the proposed amendment to § 1.1471–6(g) is the same as the text of § 1.1471–6T(g) published elsewhere in this issue of the Federal Register]. (h) * * * (2) [The text of the proposed amendment to § 1.1471–6(h)(2) is the same as the text of § 1.1471–6T(h)(2) introductory text through (h)(2)(iii) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 8. Section 1.1472–1 is amended by: ■ 1. By redesignating paragraph (f) as paragraph (h). ■ 2. By adding paragraphs (c)(1)(vi) through (vii), (c)(3) through (5), (f), and (g). ■ 3. By revising paragraphs (b)(1) introductory text, (b)(2), (c)(1) introductory text, (c)(1)(i) introductory text, (c)(1)(ii) through (iii), (c)(1)(iv) introductory text, (c)(1)(iv)(C), (c)(1)(v), (c)(2), and (d)(1) through (2). The additions and revisions read as follows: VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 § 1.1472–1 Withholding on NFFEs. * * * * * (b) * * * (1) [The text of the proposed amendment to § 1.1472–1(b)(1) is the same as the text of § 1.1472–1T(b)(1) published elsewhere in this issue of the Federal Register]. * * * * * (2) [The text of the proposed amendment to § 1.1472–1(b)(2) is the same as the text of § 1.1472–1T(b)(2) published elsewhere in this issue of the Federal Register]. (c) * * * (1) [The text of the proposed amendment to § 1.1472–1(c)(1) is the same as the text of § 1.1472–1T(c)(1) published elsewhere in this issue of the Federal Register]. (i) [The text of the proposed amendment to § 1.1472–1(c)(1)(i) introductory text is the same as the text of § 1.1472–1T(c)(1)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1472–1(c)(1)(ii) is the same as the text of § 1.1472–1T(c)(1)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of the proposed amendment to § 1.1472–1(c)(1)(iii) is the same as the text of § 1.1472–1T(c)(1)(iii) published elsewhere in this issue of the Federal Register]. (iv) [The text of the proposed amendment to § 1.1472–1(c)(1)(iv) introductory text is the same as the text of § 1.1472–1T(c)(1)(iv) published elsewhere in this issue of the Federal Register]. * * * * * (C) [The text of the proposed amendment to § 1.1472–1(c)(1)(iv)(C) is the same as the text of § 1.1472– 1T(c)(1)(iv)(C) published elsewhere in this issue of the Federal Register]. (v) [The text of the proposed amendment to § 1.1472–1(c)(1)(v) is the same as the text of § 1.1472–1T(c)(1)(v) published elsewhere in this issue of the Federal Register]. (vi) [The text of proposed § 1.1472– 1(c)(1)(vi) is the same as the text of § 1.1472–1T(c)(1)(vi) published elsewhere in this issue of the Federal Register]. (vii) [The text of proposed § 1.1472– 1(c)(1)(vii) is the same as the text of § 1.1472–1T(c)(1)(vii) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1472–1(c)(2) is the same as the text of § 1.1472–1T(c)(2) published elsewhere in this issue of the Federal Register]. PO 00000 Frm 00010 Fmt 4701 Sfmt 4702 (3) [The text of proposed § 1.1472– 1(c)(3) is the same as the text of § 1.1472–1T(c)(3) published elsewhere in this issue of the Federal Register]. (4) [The text of proposed § 1.1472– 1(c)(4) is the same as the text of § 1.1472–1T(c)(4) published elsewhere in this issue of the Federal Register]. (5) [The text of proposed § 1.1472– 1(c)(5) is the same as the text of § 1.1472–1T(c)(5) published elsewhere in this issue of the Federal Register]. (d) * * * (1) [The text of the proposed amendment to § 1.1472–1(d)(1) is the same as the text of § 1.1472–1T(d)(1) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1472–1(d)(2) is the same as the text of § 1.1472–1T(d)(2) published elsewhere in this issue of the Federal Register]. * * * * * (f) [The text of proposed § 1.1472–1(f) is the same as the text of § 1.1472–1T(f) published elsewhere in this issue of the Federal Register]. (g) [The text of proposed § 1.1472–1(g) is the same as the text of § 1.1472–1T(g) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 9. Section 1.1473–1 is amended by: ■ 1. Adding new paragraph (a)(4)(vii). ■ 2. Revising paragraphs (a)(2)(vi), (a)(3)(iii)(B)(4), (a)(4)(vi), (a)(5)(i) through (vi), and (b)(2)(v). The addition and revisions read as follows: § 1.1473–1 Section 1473 definitions. (a) * * * (2) * * * (vi) [The text of the proposed amendment to § 1.1473–1(a)(2)(vi) is the same as the text of § 1.1473–1T(a)(2)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (3) * * * (iii) * * * (B) * * * (4) [The text of the proposed amendment to § 1.1473–1(a)(3)(iii)(B)(4) is the same as the text of § 1.1473– 1T(a)(3)(iii)(B)(4) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (vi) [The text of the proposed amendment to § 1.1473–1(a)(4)(vi) is the same as the text of § 1.1473–1T(a)(4)(vi) published elsewhere in this issue of the Federal Register]. (vii) [The text of proposed § 1.1473– 1(a)(4)(vii) is the same as the text of E:\FR\FM\06MRP2.SGM 06MRP2 tkelley on DSK3SPTVN1PROD with PROPOSALS2 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules § 1.1473–1T(a)(4)(vii) published elsewhere in this issue of the Federal Register]. (5) * * * (i) [The text of the proposed amendment to § 1.1473–1(a)(5)(i) is the same as the text of § 1.1473–1T(a)(5)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1473–1(a)(5)(ii) is the same as the text of § 1.1473–1T(a)(5)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of the proposed amendment to § 1.1473–1(a)(5)(iii) is the same as the text of § 1.1473–1T(a)(5)(iii) published elsewhere in this issue of the Federal Register]. (iv) [The text of the proposed amendment to § 1.1473–1(a)(5)(iv) is the same as the text of § 1.1473–1T(a)(5)(iv) published elsewhere in this issue of the Federal Register]. (v) [The text of the proposed amendment to § 1.1473–1(a)(5)(v) is the same as the text of § 1.1473–1T(a)(5)(v) published elsewhere in this issue of the Federal Register]. (vi) [The text of the proposed amendment to § 1.1473–1(a)(5)(vi) is the same as the text of § 1.1473–1T(a)(5)(vi) published elsewhere in this issue of the Federal Register]. * * * * * (b) * * * (2) * * * (v) [The text of the proposed amendment to § 1.1473–1(b)(2)(v) is the same as the text of § 1.1473–1T(b)(2)(v) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 10. Section 1.1474–1 is amended: ■ 1. By removing paragraphs (d)(1)(ii)(A)(1)(ix), (d)(3)(iii), and (i)(1)(iv) through (v). ■ 2. By redesignating paragraphs (d)(1)(ii)(A)(1)(x) through (xii) as (d)(1)(ii)(A)(1)(ix) through (xi), and paragraphs (d)(3)(iv) through (x) as (d)(3)(iii) through (ix). ■ 3. By revising paragraphs (d)(1)(i), (d)(1)(ii)(A)(1)(viii) through (ix), (d)(1)(ii)(B)(1)(i), (d)(1)(ii)(B)(1)(vi) through (vii), (d)(1)(ii)(B)(1)(ix), (d)(2)(i), (d)(4)(i)(B), (d)(4)(i)(E), (d)(4)(ii)(B), (d)(4)(iii), (i)(1) introductory text, (i)(1)(i) through (iii), (i)(2) introductory text, and (i)(2)(iii). The additions and revisions read as follows: § 1.1474–1 Liability for withheld tax and withholding agent reporting. * * * * * (d) * * * (1) * * * (i) [The text of the proposed amendment to § 1.1474–1(d)(1)(i) is the VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 same as the text of § 1.1474–1T(d)(1)(i) published elsewhere in this issue of the Federal Register]. (ii) * * * (A) * * * (1) * * * (viii) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(A)(1)(viii) is the same as the text of § 1.1474–1T(d)(1)(ii)(A)(1)(viii) published elsewhere in this issue of the Federal Register]. (ix) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(A)(1)(ix) is the same as the text of § 1.1474–1T(d)(1)(ii)(A)(1)(ix) published elsewhere in this issue of the Federal Register]. * * * * * (B) * * * (1) * * * (i) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(B)(1)(i) is the same as the text of § 1.1474–1T(d)(1)(ii)(B)(1)(i) published elsewhere in this issue of the Federal Register]. * * * * * (vi) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(B)(1)(vi) is the same as the text of § 1.1474–1T(d)(1)(ii)(B)(1)(vi) published elsewhere in this issue of the Federal Register]. (vii) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(B)(1)(vii) is the same as the text of § 1.1474–1T(d)(1)(ii)(B)(1)(vii) published elsewhere in this issue of the Federal Register]. * * * * * (ix) [The text of the proposed amendment to § 1.1474– 1(d)(1)(ii)(B)(1)(ix) is the same as the text of § 1.1474–1T(d)(1)(ii)(B)(1)(ix) published elsewhere in this issue of the Federal Register]. * * * * * (2) * * * (i) [The text of the proposed amendment to § 1.1474–1(d)(2)(i) is the same as the text of § 1.1474–1T(d)(2)(i) through (d)(2)(i)(C) published elsewhere in this issue of the Federal Register]. * * * * * (4) * * * (i) * * * (B) [The text of the proposed amendment to § 1.1474–1(d)(4)(i)(B) is the same as the text of § 1.1474– 1T(d)(4)(i)(B) published elsewhere in this issue of the Federal Register]. * * * * * (E) [The text of the proposed amendment to § 1.1474–1(d)(4)(i)(E) is the same as the text of § 1.1474– 1T(d)(4)(i)(E) published elsewhere in this issue of the Federal Register]. PO 00000 Frm 00011 Fmt 4701 Sfmt 4702 12877 (ii) * * * (B) [The text of the proposed amendment to § 1.1474–1(d)(4)(ii)(B) is the same as the text of § 1.1474– 1T(d)(4)(ii)(B) published elsewhere in this issue of the Federal Register]. (C) [The text of the proposed amendment to § 1.1474–1(d)(4)(ii)(C) is the same as the text of § 1.1474– 1T(d)(4)(ii)(C) published elsewhere in this issue of the Federal Register]. (iii) * * * [The text of the proposed amendment to § 1.1474–1(d)(4)(iii) is the same as the text of § 1.1474–1T(d)(4)(iii) through (d)(4)(iii)(C) published elsewhere in this issue of the Federal Register]. * * * * * (i) * * * (1) [The text of the proposed amendment to § 1.1474–1(i)(1) introductory text is the same as the text of § 1.1474–1T(i)(1) published elsewhere in this issue of the Federal Register]. (i) [The text of the proposed amendment to § 1.1474–1(i)(1)(i) is the same as the text of § 1.1474–1T(i)(1)(i) published elsewhere in this issue of the Federal Register]. (ii) [The text of the proposed amendment to § 1.1474–1(i)(1)(ii) is the same as the text of § 1.1474–1T(i)(1)(ii) published elsewhere in this issue of the Federal Register]. (iii) [The text of the proposed amendment to § 1.1474–1(i)(1)(iii) is the same as the text of § 1.1474–1T(i)(1)(iii) published elsewhere in this issue of the Federal Register]. (2) [The text of the proposed amendment to § 1.1474–1(i)(2) introductory text is the same as the text of § 1.1474–1T(i)(2) published elsewhere in this issue of the Federal Register]. * * * * * (iii) [The text of the proposed amendment to § 1.1474–1(i)(2)(iii) is the same as the text of § 1.1474–1T(i)(2)(iii) published elsewhere in this issue of the Federal Register]. * * * * * ■ Par. 11. Section 1.1474–6 is amended by: ■ 1. Revising paragraph (b)(1). ■ 2. Redesignating paragraph (f) as paragraph (g). ■ 3. Adding new paragraph (f). The revision and addition read as follows: § 1.1474–6 Coordination of chapter 4 with other withholding provisions. * * * * * (b) * * * (1) [The text of the proposed amendment to § 1.1474–6(b)(1) is the E:\FR\FM\06MRP2.SGM 06MRP2 12878 Federal Register / Vol. 79, No. 44 / Thursday, March 6, 2014 / Proposed Rules same as the text of § 1.1474–6T(b)(1) published elsewhere in this issue of the Federal Register]. * * * * * (f) [The text of proposed § 1.1474–6(f) is the same as the text of § 1.1474–6T(f) published elsewhere in this issue of the Federal Register]. * * * * * John Dalrymple, Deputy Commissioner for Services and Enforcement. [FR Doc. 2014–03960 Filed 2–28–14; 4:15 pm] tkelley on DSK3SPTVN1PROD with PROPOSALS2 BILLING CODE 4830–01–P VerDate Mar<15>2010 18:30 Mar 05, 2014 Jkt 232001 PO 00000 Frm 00012 Fmt 4701 Sfmt 9990 E:\FR\FM\06MRP2.SGM 06MRP2

Agencies

[Federal Register Volume 79, Number 44 (Thursday, March 6, 2014)]
[Proposed Rules]
[Pages 12867-12878]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-03960]



[[Page 12867]]

Vol. 79

Thursday,

No. 44

March 6, 2014

Part IV





Department of the Treasury





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Internal Revenue Service





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26 CFR Part 1





Regulations Relating to Information Reporting by Foreign Financial 
Institutions and Withholding on Certain Payments to Foreign Financial 
Institutions and Other Foreign Entities; Proposed Rule

Federal Register / Vol. 79 , No. 44 / Thursday, March 6, 2014 / 
Proposed Rules

[[Page 12868]]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-130967-13]
RIN 1545-BL72


Regulations Relating to Information Reporting by Foreign 
Financial Institutions and Withholding on Certain Payments to Foreign 
Financial Institutions and Other Foreign Entities

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary 
regulations and notice of public hearing.

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SUMMARY: In this issue of the Federal Register, the IRS and the 
Department of the Treasury (Treasury Department) are issuing final and 
temporary regulations that provide guidance under chapter 4 of Subtitle 
A (sections 1471 through 1474) of the Internal Revenue Code of 1986 
(Code). These regulations address reporting by foreign financial 
institutions (FFIs) with respect to U.S. accounts and withholding on 
certain payments to FFIs and other foreign entities. The text of the 
temporary regulations published in the Federal Register also serves as 
the text of these proposed regulations. This document also provides 
notice of a public hearing on these proposed regulations.

DATES: Written and/or electronic comments must be received by May 5, 
2014. Outlines of topics to be discussed at the public hearing 
scheduled for June 24, 2014, at 10 a.m. must be received by May 5, 
2014.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-130967-13), 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 8:00 a.m. and 4:00 p.m. to CC:PA:LPD:PR 
(REG-130967-13), Courier's Desk, Internal Revenue Service, 1111 
Constitution Avenue NW., Washington, DC 20224, or sent electronically, 
via the Federal eRulemaking Portal at www.regulations.gov (IRS REG-
130967-13). 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 proposed regulations, 
Tara Ferris, Nancy Lee, Michael Kaercher, or Kamela Nelan at (202) 317-
6942; concerning submission of comments, the hearing, and/or to be 
placed on the building access list to attend the hearing, 
Oluwafunmilayo (Funmi) Taylor, at (202) 317-5179 (not toll-free 
numbers).

SUPPLEMENTARY INFORMATION:

Background

    Temporary regulations in this issue of the Federal Register amend 
the Income Tax Regulations (26 CFR part 1) under chapter 4 of Subtitle 
A of the Code. The temporary regulations set forth rules relating to 
information reporting by FFIs with respect to U.S. accounts and 
withholding on certain payments to FFIs and other foreign entities. The 
temporary regulations revise and refine final regulations (TD 9610) 
under chapter 4 that were published in the Federal Register (78 FR 
5874) on January 28, 2013, as corrected on September 10, 2013 (78 FR 
55202). The text of the temporary regulations also serves as the text 
of these proposed regulations. The preamble to the temporary 
regulations explains the temporary regulations and these proposed 
regulations.

Special Analyses

    It has been determined that this notice of proposed rulemaking is 
not a significant regulatory action as defined in Executive Order 
12866, as supplemented by Executive Order 13653. 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.
    It is hereby certified that the collection of information in this 
notice of proposed rulemaking will not have a significant economic 
impact on a substantial number of small business entities within the 
meaning of section 601(6) of the Regulatory Flexibility Act (5 U.S.C. 
chapter 6). Although the Treasury Department and the IRS anticipate 
that a substantial number of domestic small business entities will be 
affected by the collection of information in this notice of proposed 
rulemaking, the Treasury Department and the IRS believe that the 
economic impact to these entities resulting from the information 
collection requirements will not be significant.
    The domestic small business entities that are subject to chapter 4 
and the collection of information in this notice of proposed rulemaking 
are those domestic business entities that are payors of certain U.S. 
source income that are presently subject to the information collection 
and reporting rules under chapter 3. These domestic small business 
entities are required to be familiar with chapter 3's information 
collection and reporting rules and forms in order to determine a 
payee's U.S. withholding status and, based on that status, withhold and 
remit the proper amount of tax on payments of U.S. source FDAP income. 
Small domestic business entities that are payors of U.S. source income 
have developed and implemented internal reporting and information 
collection systems under which the business entity satisfies its 
chapter 3 payee identification, withholding, and tax remittance 
requirements.
    The IRS intends to revise the present chapter 3 reporting forms, 
with the revised forms being used by a payor of U.S. source income to 
satisfy the payor's obligations under chapters 3 and 4. As a result, 
the information collection requirements of this notice of proposed 
rulemaking build on reporting and information collection systems 
familiar to and currently used by payors of U.S. source FDAP income 
that are domestic small business entities. Because the information 
collection and reporting requirements of chapter 4 and this notice of 
proposed rulemaking build on existing chapter 3 information collection 
and reporting systems of domestic small business entities making 
payments of U.S. source income to foreign persons, the information 
collection requirements of this notice of proposed rulemaking impose 
little additional burden on those domestic entities. Therefore, a 
Regulatory Flexibility Analysis under the Regulatory Flexibility Act is 
not required.
    Pursuant to section 7805(f) of the Code, this regulation has been 
submitted to the Chief Counsel for Advocacy of the Small Business 
Administration for comment on its impact on small businesses. The IRS 
invites the public to comment on this certification.

Comments and 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. The IRS and the Treasury Department request comments on all 
aspects of the proposed regulations. All comments will be available for 
public inspection and copying.
    A public hearing has been scheduled for June 24, 2014, beginning at 
10 a.m. in the Auditorium, Internal Revenue Building, 1111 Constitution 
Avenue NW., Washington, DC. Due to building security procedures, 
visitors must enter

[[Page 12869]]

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 area 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, an outline of the topics to be discussed, and the 
time to be devoted to each topic. Submit a signed original and eight 
(8) copies or an electronic copy of the topics outline by May 5, 2014. 
A period of 10 minutes 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 authors of these regulations are Tara Ferris, Nancy 
Lee, Michael Kaercher, and Kamela Nelan of the Office of Associate 
Chief Counsel (International). However, other personnel from the IRS 
and the Treasury Department participated in the development of these 
regulations.

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

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805. * * *
    Section 1.1471-1 is also issued under 26 U.S.C. 1471.
    Section 1.1471-2 is also issued under 26 U.S.C. 1471.
    Section 1.1471-3 is also issued under 26 U.S.C. 1471.
    Section 1.1471-4 is also issued under 26 U.S.C. 1471.
    Section 1.1471-5 is also issued under 26 U.S.C. 1471.
    Section 1.1471-6 is also issued under 26 U.S.C. 1471.
    Section 1.1472-1 is also issued under 26 U.S.C. 1472.
    Section 1.1471-3 is also issued under 26 U.S.C. 1473.
    Section 1.1474-1 is also issued under 26 U.S.C. 1474.
    Section 1.1474-6 is also issued under 26 U.S.C. 1474.

0
Par. 2. Section 1.1471-1 is amended by:
0
1. Removing paragraph (b)(81).
0
2. Redesignating paragraphs (b)(115) through (b)(142) as (b)(124) 
through (b)(151), paragraphs (b)(108) through (b)(114) as (b)(116) 
through (b)(122), paragraph (b)(107) as (b)(114), paragraphs (b)(82) 
through (b)(106) as (b)(88) through (b)(112), paragraphs (b)(75) 
through (b)(80) as (b)(82) through (b)(87), paragraphs (b)(62) through 
(b)(74) as (b)(68) through (b)(80), paragraphs (b)(39) through (b)(61) 
as (b)(44) through (b)(66), paragraphs (b)(28) through (b)(38) as 
(b)(32) through (b)(42), paragraphs (b)(18) through (b)(27) as (b)(21) 
through (b)(30), paragraphs (b)(9) through (b)(17) as (b)(11) through 
(b)(19), and paragraphs (b)(7) and (b)(8) as (b)(8) and (b)(9).
0
3. Adding new paragraphs (b)(7), (b)(10), (b)(20), (b)(31), (b)(43), 
(b)(67), (b)(81), (b)(113), (b)(115), and (b)(123).
0
4. Revising paragraphs (b)(23), (b)(35), (b)(41), (b)(48), (b)(50), 
(b)(76), (b)(77), (b)(83), (b)(88), (b)(91), (b)(98), (b)(100), 
(b)(104)(i), (b)(104)(ii)(A) through (C), (b)(105), (b)(124), (b)(125), 
(b)(128), (b)(135) and (b)(141).
    The revisions and additions read as follows:


Sec.  1.1471-1  Scope of chapter 4 and definitions.

* * * * *
    (b) * * *
    (7) [The text of proposed Sec.  1.1471-1(b)(7) is the same as the 
text of Sec.  1.1471-1T(b)(7) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (10) [The text of proposed Sec.  1.1471-1(b)(10) is the same as the 
text of Sec.  1.1471-1T(b)(10) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (20) [The text of proposed Sec.  1.1471-1(b)(20) is the same as the 
text of Sec.  1.1471-1T(b)(20) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (23) [The text of the proposed amendment to Sec.  1.1471-1(b)(23) 
is the same as the text of Sec.  1.1471-1T(b)(23) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (31) [The text of proposed Sec.  1.1471-1(b)(31) is the same as the 
text of Sec.  1.1471-1T(b)(31) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (35) [The text of the proposed amendment to Sec.  1.1471-1(b)(35) 
is the same as the text of Sec.  1.1471-1T(b)(35) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (41) [The text of the proposed amendment to Sec.  1.1471-1(b)(41) 
is the same as the text of Sec.  1.1471-1T(b)(41) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (43) [The text of proposed Sec.  1.1471-1(b)(43) is the same as the 
text of Sec.  1.1471-1T(b)(43) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (48) [The text of the proposed amendment to Sec.  1.1471-1(b)(48) 
is the same as the text of Sec.  1.1471-1T(b)(48) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (50) [The text of the proposed amendment to Sec.  1.1471-1(b)(50) 
is the same as the text of Sec.  1.1471-1T(b)(50) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (67) [The text of proposed Sec.  1.1471-1(b)(67) is the same as the 
text of Sec.  1.1471-1T(b)(67) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (76) [The text of the proposed amendment to Sec.  1.1471-1(b)(76) 
is the same as the text of Sec.  1.1471-1T(b)(76) published elsewhere 
in this issue of the Federal Register].
    (77) [The text of the proposed amendment to Sec.  1.1471-1(b)(77) 
is the same as the text of Sec.  1.1471-1T(b)(77) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (81) [The text of proposed Sec.  1.1471-1(b)(81) is the same as the 
text of Sec.  1.1471-1T(b)(81) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (83) [The text of the proposed amendment to Sec.  1.1471-1(b)(83) 
is the same as the text of Sec.  1.1471-1T(b)(83) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (88) [The text of the proposed amendment to Sec.  1.1471-1(b)(88) 
is the same as the text of Sec.  1.1471-1T(b)(88) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (91) [The text of the proposed amendment to Sec.  1.1471-1(b)(91) 
is the same as the text of Sec.  1.1471-1T(b)(91) published elsewhere 
in this issue of the Federal Register].
* * * * *

[[Page 12870]]

    (98) [The text of the proposed amendment to Sec.  1.1471-1(b)(98) 
is the same as the text of Sec.  1.1471-1T(b)(98) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (100) [The text of the proposed amendment to Sec.  1.1471-1(b)(100) 
is the same as the text of Sec.  1.1471-1T(b)(100) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (104) * * * (i) [The text of the proposed amendment to Sec.  
1.1471-1(b)(104)(i) is the same as the text of Sec.  1.1471-
1T(b)(104)(i) published elsewhere in this issue of the Federal 
Register].
    (ii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
1(b)(104)(ii)(A) is the same as the text of Sec.  1.1471-
1T(b)(104)(ii)(A) published elsewhere in this issue of the Federal 
Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
1(b)(104)(ii)(B) is the same as the text of Sec.  1.1471-
1T(b)(104)(ii)(B) published elsewhere in this issue of the Federal 
Register].
    (C) [The text of the proposed amendment to Sec.  1.1471-
1(b)(104)(ii)(C) is the same as the text of Sec.  1.1471-
1T(b)(104)(ii)(C) published elsewhere in this issue of the Federal 
Register].
    (105) [The text of the proposed amendment to Sec.  1.1471-1(b)(105) 
is the same as the text of Sec.  1.1471-1T(b)(105) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (113) [The text of proposed Sec.  1.1471-1(b)(113) is the same as 
the text of Sec.  1.1471-1T(b)(113) published elsewhere in this issue 
of the Federal Register].
* * * * *
    (115) [The text of proposed Sec.  1.1471-1(b)(115) is the same as 
the text of Sec.  1.1471-1T(b)(115) published elsewhere in this issue 
of the Federal Register].
* * * * *
    (123) [The text of proposed Sec.  1.1471-1(b)(123) is the same as 
the text of Sec.  1.1471-1T(b)(123) published elsewhere in this issue 
of the Federal Register].
    (124) [The text of the proposed amendment to Sec.  1.1471-1(b)(124) 
is the same as the text of Sec.  1.1471-1T(b)(124) published elsewhere 
in this issue of the Federal Register].
    (125) [The text of the proposed amendment to Sec.  1.1471-1(b)(125) 
is the same as the text of Sec.  1.1471-1T(b)(125) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (128) [The text of the proposed amendment to Sec.  1.1471-1(b)(128) 
is the same as the text of Sec.  1.1471-1T(b)(128) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (135) [The text of the proposed amendment to Sec.  1.1471-1(b)(135) 
is the same as the text of Sec.  1.1471-1T(b)(135) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (141) [The text of the proposed amendment to Sec.  1.1471-1(b)(141) 
is the same as the text of Sec.  1.1471-1T(b)(141) published elsewhere 
in this issue of the Federal Register].
* * * * *
0
Par. 3. In Sec.  1.1471-2,
0
a. Revise paragraphs (a)(1), (a)(2)(i), (a)(2)(ii) introductory text, 
(a)(2)(iii)(A), and (a)(2)(v).
0
b. Remove the heading of paragraph (a)(4)(ii), and add introductory 
text to paragraph (a)(4)(ii).
0
c. Revise paragraphs (a)(4)(ii)(A), (a)(4)(ii)(B), (b)(2)(i)(A)(1), 
(b)(2)(ii)(A)(4), (b)(2)(ii)(B)(2), (b)(2)(iv), and (b)(4)(ii).
    The revisions read as follows:


Sec.  1.1471-2  Requirement to deduct and withhold tax on withholdable 
payments to certain FFIs.

    (a) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-2(a)(1) is 
the same as the text of Sec.  1.1471-2T(a)(1) published elsewhere in 
this issue of the Federal Register].
    (2) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-2(a)(2)(i) 
is the same as the text of Sec.  1.1471-2T(a)(2)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1471-
2(a)(2)(ii) introductory text is the same as the text of Sec.  1.1471-
2T(a)(2)(ii) published elsewhere in this issue of the Federal 
Register].
    (iii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
2(a)(2)(iii)(A) is the same as the text of Sec.  1.1471-
2T(a)(2)(iii)(A) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (v) [The text of the proposed amendment to Sec.  1.1471-2(a)(2)(v) 
is the same as the text of Sec.  1.1471-2T(a)(2)(v) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (4) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
2(a)(4)(ii) is the same as the text of Sec.  1.1471-2T(a)(4)(ii) 
published elsewhere in this issue of the Federal Register].
    (A) [The text of the proposed amendment to Sec.  1.1471-
2(a)(4)(ii)(A) is the same as the text of Sec.  1.1471-2T(a)(4)(ii)(A) 
published elsewhere in this issue of the Federal Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
2(a)(4)(ii)(B) is the same as the text of Sec.  1.1471-2T(a)(4)(ii)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (b) * * *
    (2) * * *
    (i) * * *
    (A) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
2(b)(2)(i)(A)(1) is the same as the text of Sec.  1.1471-
2T(b)(2)(i)(A)(1) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (ii) * * *
    (A) * * *
    (4) [The text of the proposed amendment to Sec.  1.1471-
2(b)(2)(ii)(A)(4) is the same as the text of Sec.  1.1471-
2T(b)(2)(ii)(A)(4) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (B) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-
2(b)(2)(ii)(B)(2) is the same as the text of Sec.  1.1471-
2T(b)(2)(ii)(B)(2) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (iv) [The text of the proposed amendment to Sec.  1.1471-
2(b)(2)(iv) is the same as the text of Sec.  1.1471-2T(b)(2)(iv) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (4) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
2(b)(4)(ii) is the same as the text of Sec.  1.1471-2T(b)(4)(ii) 
published elsewhere in this issue of the Federal Register].
* * * * *
0
Par. 4. Section 1.1471-3 is amended by:
0
1. By adding paragraphs (c)(6)(ii)(B)(7), (c)(8)(v), (d)(5)(iii), and 
(d)(11)(x) through (xii).
0
2. By revising paragraphs (a)(3)(iii), (a)(3)(v) through (vi), (b)(3), 
(c)(3)(ii)(C) through (D), (c)(3)(iii)(A) introductory text, 
(c)(3)(iii)(A)(5), (c)(3)(iii)(B)(1) through (4), (c)(5)(ii)(B), 
(c)(6)(ii)(B)(3), (c)(6)(ii)(B)(5) through (6), (c)(6)(ii)(C)(3) 
through (5), (c)(6)(ii)(E)(3), (c)(6)(iv), (c)(6)(v)(A) through (B), 
(c)(9)(ii)(B), (c)(9)(v), (d)(1), (d)(2)(i), (d)(2)(iii), (d)(4)(i) and 
(ii), (d)(4)(iii) introductory

[[Page 12871]]

text, (d)(4)(iii)(A)(1), (d)(4)(iv)(A), (d)(4)(iv)(C) through (D), 
(d)(4)(v), (d)(5)(i) through (ii), (d)(6)(vii)(A)(1), (d)(11)(viii)(A) 
introductory text, (d)(11)(viii)(C), (d)(12)(iii)(A) through (B), 
(e)(2) through (3), (e)(4) introductory text, (e)(4)(i) through (iv), 
(e)(4)(v) introductory text, (e)(4)(v)(B)(1) through (2), 
(e)(4)(vi)(B), (e)(4)(vii)(B), (e)(4)(viii)(A)(4), and (f)(1) through 
(9).
    The revisions and additions read as follows:


Sec.  1.1471-3  Identification of payee.

    (a) * * *
    (3) * * *
    (iii) [The text of the proposed amendment to Sec.  1.1471-
3(a)(3)(iii) is the same as the text of Sec.  1.1471-3T(a)(3)(iii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (v) [The text of the proposed amendment to Sec.  1.1471-3(a)(3)(v) 
is the same as the text of Sec.  1.1471-3T(a)(3)(v) published elsewhere 
in this issue of the Federal Register].
    (vi) [The text of the proposed amendment to Sec.  1.1471-
3(a)(3)(vi) is the same as the text of Sec.  1.1471-3T(a)(3)(vi) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (b) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-3(b)(3) is 
the same as the text of Sec.  1.1471-3T(b)(3) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (c) * * *
    (3) * * *
    (ii) * * *
    (C) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(ii)(C) is the same as the text of Sec.  1.1471-3T(c)(3)(ii)(C) 
published elsewhere in this issue of the Federal Register].
    (D) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(ii)(D) is the same as the text of Sec.  1.1471-3T(c)(3)(ii)(D) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (iii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(A) introductory text is the same as the text of Sec.  
1.1471-3T(c)(3)(iii)(A) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (5) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(A)(5) is the same as the text of Sec.  1.1471-
3T(c)(3)(iii)(A)(5) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (B) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(B)(1) is the same as the text of Sec.  1.1471-
3T(c)(3)(iii)(B)(1) published elsewhere in this issue of the Federal 
Register].
    (2) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(B)(2) is the same as the text of Sec.  1.1471-
3T(c)(3)(iii)(B)(2) published elsewhere in this issue of the Federal 
Register].
    (3) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(B)(3) is the same as the text of Sec.  1.1471-
3T(c)(3)(iii)(B)(3) published elsewhere in this issue of the Federal 
Register].
    (4) [The text of the proposed amendment to Sec.  1.1471-
3(c)(3)(iii)(B)(4) is the same as the text of Sec.  1.1471-
3T(c)(3)(iii)(B)(4) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (5) * * *
    (ii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(c)(5)(ii)(B) is the same as the text of Sec.  1.1471-3T(c)(5)(ii)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (6) * * *
    (ii) * * *
    (B) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(B)(3) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(B)(3) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (5) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(B)(5) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(B)(5) published elsewhere in this issue of the Federal 
Register].
    (6) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(B)(6) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(B)(6) published elsewhere in this issue of the Federal 
Register].
    (7) [The text of proposed Sec.  1.1471-3(c)(6)(ii)(B)(7) is the 
same as the text of Sec.  1.1471-3T(c)(6)(ii)(B)(7) published elsewhere 
in this issue of the Federal Register].
    (C) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(C)(3) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(C)(3) published elsewhere in this issue of the Federal 
Register].
    (4) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(C)(4) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(C)(4) published elsewhere in this issue of the Federal 
Register].
    (5) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(C)(5) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(C)(5) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (E) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(ii)(E)(3) is the same as the text of Sec.  1.1471-
3T(c)(6)(ii)(E)(3) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (iv) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(iv) is the same as the text of Sec.  1.1471-3T(c)(6)(iv) 
published elsewhere in this issue of the Federal Register].
    (v) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(v)(A) is the same as the text of Sec.  1.1471-3T(c)(6)(v)(A) 
published elsewhere in this issue of the Federal Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(c)(6)(v)(B) is the same as the text of Sec.  1.1471-3T(c)(6)(v)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (8) * * *
    (v) [The text of proposed Sec.  1.1471-3(c)(8)(v) is the same as 
the text of Sec.  1.1471-3T(c)(8)(v) published elsewhere in this issue 
of the Federal Register].
    (9) * * *
    (ii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(c)(9)(ii)(B) is the same as the text of Sec.  1.1471-3T(c)(9)(ii)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (v) [The text of the proposed amendment to Sec.  1.1471-3(c)(9)(v) 
is the same as the text of Sec.  1.1471-3T(c)(9)(v) published elsewhere 
in this issue of the Federal Register].
    (d) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-3(d)(1) is 
the same as the text of Sec.  1.1471-3T(d)(1) published elsewhere in 
this issue of the Federal Register].
    (2) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-3(d)(2)(i) 
is the same as the text of Sec.  1.1471-3T(d)(2)(i) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (iii) [The text of the proposed amendment to Sec.  1.1471-
3(d)(2)(iii) is the same as the text of Sec.  1.1471-3T(d)(2)(iii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (4) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-3(d)(4)(i) 
is the

[[Page 12872]]

same as the text of Sec.  1.1471-3T(d)(4)(i) published elsewhere in 
this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(ii) is the same as the text of Sec.  1.1471-3T(d)(4)(ii) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(iii) introductory text is the same as the text of Sec.  1.1471-
3T(d)(4)(iii) published elsewhere in this issue of the Federal 
Register].
    (A) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(iii)(A)(1) is the same as the text of Sec.  1.1471-
3T(d)(4)(iii)(A)(1) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (iv) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(iv)(A) is the same as the text of Sec.  1.1471-3T(d)(4)(iv)(A) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (C) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(iv)(C) is the same as the text of Sec.  1.1471-3T(d)(4)(iv)(C) 
published elsewhere in this issue of the Federal Register].
    (D) [The text of the proposed amendment to Sec.  1.1471-
3(d)(4)(iv)(D) is the same as the text of Sec.  1.1471-3T(d)(4)(iv)(D) 
published elsewhere in this issue of the Federal Register].
    (v) [The text of the proposed amendment to Sec.  1.1471-3(d)(4)(v) 
is the same as the text of Sec.  1.1471-3T(d)(4)(v) published elsewhere 
in this issue of the Federal Register].
    (5) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-3(d)(5)(i) 
is the same as the text of Sec.  1.1471-3T(d)(5)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1471-
3(d)(5)(ii) is the same as the text of Sec.  1.1471-3T(d)(5)(ii)(A) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of proposed Sec.  1.1471-3(d)(5)(iii) is the same 
as the text of Sec.  1.1471-3T(d)(5)(iii) published elsewhere in this 
issue of the Federal Register].
    (6) * * *
    (vii) * * *
    (A) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
3(d)(6)(vii)(A)(1) is the same as the text of Sec.  1.1471-
3T(d)(6)(vii)(A)(1) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (11) * * *
    (viii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
3(d)(11)(viii)(A) introductory text is the same as the text of Sec.  
1.1471-3T(d)(11)(viii)(A) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (C) [The text of the proposed amendment to Sec.  1.1471-
3(d)(11)(viii)(C) is the same as the text of Sec.  1.1471-
3T(d)(11)(vii)(C) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (x) [The text of proposed Sec.  1.1471-3(d)(11)(x) is the same as 
the text of Sec.  1.1471-3T(d)(11)(x) published elsewhere in this issue 
of the Federal Register].
    (xi) [The text of proposed Sec.  1.1471-3(d)(11)(xi) is the same as 
the text of Sec.  1.1471-3T(d)(11)(xi) published elsewhere in this 
issue of the Federal Register].
    (xii) [The text of proposed Sec.  1.1471-3(d)(11)(xii) is the same 
as the text of Sec.  1.1471-3T(d)(11)(xii) published elsewhere in this 
issue of the Federal Register].
    (12) * * *
    (iii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
3(d)(12)(iii)(A) is the same as the text of Sec.  1.1471-
3T(d)(12)(iii)(A) published elsewhere in this issue of the Federal 
Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(d)(12)(iii)(B) is the same as the text of Sec.  1.1471-
3T(d)(12)(iii)(B) published elsewhere in this issue of the Federal 
Register].
    (e) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-3(e)(2) is 
the same as the text of Sec.  1.1471-3T(e)(2) published elsewhere in 
this issue of the Federal Register].
    (3) [The text of proposed Sec.  1.1471-3(e)(3) is the same as the 
text of Sec.  1.1471-3T(e)(3) through (e)(3)(iv) published elsewhere in 
this issue of the Federal Register].
    (4) [The text of the proposed amendment to Sec.  1.1471-3(e)(4) 
introductory text is the same as the text of Sec.  1.1471-3T(e)(4) 
introductory text published elsewhere in this issue of the Federal 
Register].
    (i) through (iv) [The text of the proposed amendment to Sec.  
1.1471-3(e)(4)(i) through (iv) is the same as the text of Sec.  1.1471-
3T(e)(4)(i) through (iv)(B)(2) published elsewhere in this issue of the 
Federal Register].
    (v) [The text of the proposed amendment to Sec.  1.1471-3(e)(4)(v) 
introductory text is the same as the text of Sec.  1.1471-3T(e)(4)(v) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (B) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
3(e)(4)(v)(B)(1) is the same as the text of Sec.  1.1471-
3T(e)(4)(v)(B)(1) published elsewhere in this issue of the Federal 
Register].
    (2) [The text of the proposed amendment to Sec.  1.1471-
3(e)(4)(v)(B)(2) is the same as the text of Sec.  1.1471-
3T(e)(4)(v)(B)(2) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (vi) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(e)(4)(vi)(B) is the same as the text of Sec.  1.1471-3T(e)(4)(vi)(B) 
published elsewhere in this issue of the Federal Register].
    (vii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
3(e)(4)(vii)(B) is the same as the text of Sec.  1.1471-
3T(e)(4)(vii)(B) published elsewhere in this issue of the Federal 
Register].
    (viii) * * *
    (A) * * *
    (4) [The text of the proposed amendment to Sec.  1.1471-
3(e)(4)(viii)(A)(4) is the same as the text of Sec.  1.1471-
3T(e)(4)(viii)(A)(4) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (f) * * *
    (1) through (9) [The text of the proposed amendment to Sec.  
1.1471-3(f)(1) through (9) is the same as the text of Sec.  1.1471-
3T(f)(1) through (f)(9)(ii) published elsewhere in this issue of the 
Federal Register].
* * * * *
0
Par. 5. Section 1.1471-4 is amended by:
0
1. Removing paragraph (d)(3)(v).
0
2. Redesignating paragraphs (d)(3)(vi) through (viii) as paragraphs 
(d)(3)(v) through (vii) and paragraph (d)(6)(vi) as paragraph 
(d)(6)(vii).
0
3. Adding paragraphs (b)(3)(i) through (iii), (d)(2)(ii)(F), 
(d)(2)(iii)(C), and (d)(6)(vi).
0
4. Revising paragraphs (a)(3), (b)(1) through (3), (b)(6), 
(c)(5)(iv)(B)(2)(vi), (c)(5)(iv)(E), (d)(1), (d)(2)(i), (d)(2)(ii)(A), 
(d)(2)(ii)(B)(2), (d)(2)(ii)(E), (d)(2)(iii)(A), (d)(2)(iii)(B) 
introductory text, (d)(3)(ii)(E), (d)(3)(iii)(F), (d)(5)(v) through 
(vi), (d)(7)(i), (d)(7)(ii)(A), (d)(7)(iii), (d)(7)(iv)(A) through (B), 
(d)(8), (d)(9) Example 3, Example 5, and Example 7, (e)(1), (e)(2)(ii), 
(f)(4)(i) through (ii), (g)(1) introductory text, (g)(1)(ii), and 
(g)(2).

[[Page 12873]]

0
5. By removing the heading of paragraph (d)(7) and adding introductory 
text to paragraph (d)(7).
    The additions and revisions read as follows:


Sec.  1.1471-4  FFI agreement.

    (a) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-4(a)(3) is 
the same as the text of Sec.  1.1471-4T(a)(3) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (b) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-4(b)(1) is 
the same as the text of Sec.  1.1471-4T(b)(1) published elsewhere in 
this issue of the Federal Register].
    (2) [The text of the proposed amendment to Sec.  1.1471-4(b)(2) is 
the same as the text of Sec.  1.1471-4T(b)(2) published elsewhere in 
this issue of the Federal Register].
    (3) [The text of the proposed amendment to Sec.  1.1471-4(b)(3) is 
the same as the text of Sec.  1.1471-4T(b)(3) published elsewhere in 
this issue of the Federal Register].
    (i) [The text of proposed Sec.  1.1471-4(b)(3)(i) is the same as 
the text of Sec.  1.1471-4T(b)(3)(i) published elsewhere in this issue 
of the Federal Register].
    (ii) [The text of proposed Sec.  1.1471-4(b)(3)(ii) is the same as 
the text of Sec.  1.1471-4T(b)(3)(ii) published elsewhere in this issue 
of the Federal Register].
    (iii) [The text of proposed Sec.  1.1471-4(b)(3)(iii) is the same 
as the text of Sec.  1.1471-4T(b)(3)(iii) published elsewhere in this 
issue of the Federal Register].
* * * * *
    (6) [The text of the proposed amendment to Sec.  1.1471-4(b)(6) is 
the same as the text of Sec.  1.1471-4T(b)(6) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (c) * * *
    (5) * * *
    (iv) * * *
    (B) * * *
    (2) * * *
    (vi) [The text of the proposed amendment to Sec.  1.1471-
4(c)(5)(iv)(B)(2)(vi) is the same as the text of Sec.  1.1471-
4T(c)(5)(iv)(B)(2)(vi) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (E) [The text of the proposed amendment to Sec.  1.1471-
4(c)(5)(iv)(E) is the same as the text of Sec.  1.1471-4T(c)(5)(iv)(E) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (d) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-4(d)(1) is 
the same as the text of Sec.  1.1471-4T(d)(1) published elsewhere in 
this issue of the Federal Register].
    (2) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-4(d)(2)(i) 
is the same as the text of Sec.  1.1471-4T(d)(2)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
4(d)(2)(ii)(A) is the same as the text of Sec.  1.1471-4T(d)(2)(ii)(A) 
published elsewhere in this issue of the Federal Register].
    (B) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-
4(d)(2)(ii)(B)(2) is the same as the text of Sec.  1.1471-
4T(d)(2)(ii)(B)(2) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (E) [The text of the proposed amendment to Sec.  1.1471-
4(d)(2)(ii)(E) is the same as the text of Sec.  1.1471-4T(d)(2)(ii)(E) 
published elsewhere in this issue of the Federal Register].
    (F) [The text of proposed Sec.  1.1471-4(d)(2)(ii)(F) is the same 
as the text of Sec.  1.1471-4T(d)(2)(ii)(F) published elsewhere in this 
issue of the Federal Register].
    (iii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
4(d)(2)(iii)(A) is the same as the text of Sec.  1.1471-
4T(d)(2)(iii)(A) published elsewhere in this issue of the Federal 
Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
4(d)(2)(iii)(B) introductory text is the same as the text of Sec.  
1.1471-4T(d)(2)(iii)(B) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (C) [The text of proposed Sec.  1.1471-4(d)(2)(iii)(C) is the same 
as the text of Sec.  1.1471-4T(d)(2)(iii)(C) published elsewhere in 
this issue of the Federal Register].
    (3) * * *
    (ii) * * *
    (E) [The text of the proposed amendment to Sec.  1.1471-
4(d)(3)(ii)(E) is the same as the text of Sec.  1.1471-4T(d)(3)(ii)(E) 
published elsewhere in this issue of the Federal Register].
    (iii) * * *
    (F) [The text of the proposed amendment to Sec.  1.1471-
4(d)(3)(iii)(F) is the same as the text of Sec.  1.1471-
4T(d)(3)(iii)(F) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (5) * * *
    (v) [The text of the proposed amendment to Sec.  1.1471-4(d)(5)(v) 
is the same as the text of Sec.  1.1471-4T(d)(5)(v) published elsewhere 
in this issue of the Federal Register].
    (vi) [The text of the proposed amendment to Sec.  1.1471-
4(d)(5)(vi) is the same as the text of Sec.  1.1471-4T(d)(5)(vi) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (6) * * *
    (vi) [The text of proposed Sec.  1.1471-4(d)(6)(vi) is the same as 
the text of Sec.  1.1471-4T(d)(6)(vi) published elsewhere in this issue 
of the Federal Register].
* * * * *
    (7) [The text of the proposed amendment to Sec.  1.1471-4(d)(7) 
introductory text is the same as the text of Sec.  1.1471-4T(d)(7) 
introductory text published elsewhere in this issue of the Federal 
Register].
    (i) [The text of the proposed amendment to Sec.  1.1471-4(d)(7)(i) 
is the same as the text of Sec.  1.1471-4T(d)(7)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
4(d)(7)(ii)(A) is the same as the text of Sec.  1.1471-4T(d)(7)(ii)(A) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (iii) [The text of the proposed amendment to Sec.  1.1471-
4(d)(7)(iii) is the same as the text of Sec.  1.1471-4T(d)(7)(iii) 
published elsewhere in this issue of the Federal Register].
    (iv) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
4(d)(7)(iv)(A) is the same as the text of Sec.  1.1471-4T(d)(7)(iv)(A) 
published elsewhere in this issue of the Federal Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
4(d)(7)(iv)(B) is the same as the text of Sec.  1.1471-4T(d)(7)(iv)(B) 
published elsewhere in this issue of the Federal Register].
    (8) [The text of the proposed amendment to Sec.  1.1471-4(d)(8) is 
the same as the text of Sec.  1.1471-4T(d)(8) published elsewhere in 
this issue of the Federal Register].
    (9) * * *
    Example 3. [The text of the proposed amendment to Example 3 of 
Sec.  1.1471-4(d)(9) is the same as the text of Example 3 of Sec.  
1.1471-4T(d)(9) published elsewhere in this issue of the Federal 
Register].
* * * * *

[[Page 12874]]

    Example 5. [The text of the proposed amendment to Example 5 of 
Sec.  1.1471-4(d)(9) is the same as the text of Example 5 of Sec.  
1.1471-4T(d)(9) published elsewhere in this issue of the Federal 
Register].
* * * * *
    Example 7. [The text of the proposed amendment to Example 7 of 
Sec.  1.1471-4(d)(9) is the same as the text of Example 7 of Sec.  
1.1471-4T(d)(9) published elsewhere in this issue of the Federal 
Register].
    (e) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-4(e)(1) is 
the same as the text of Sec.  1.1471-4T(e)(1) published elsewhere in 
this issue of the Federal Register].
    (2) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
4(e)(2)(ii) is the same as the text of Sec.  1.1471-4T(e)(2)(ii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (f) * * *
    (4) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-4(f)(4)(i) 
is the same as the text of Sec.  1.1471-4T(f)(4)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1471-
4(f)(4)(ii) is the same as the text of Sec.  1.1471-4T(f)(4)(ii) 
published elsewhere in this issue of the Federal Register].
    (g) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-4(g)(1) 
introductory text is the same as the text of Sec.  1.1471-4T(g)(1) 
introductory text published elsewhere in this issue of the Federal 
Register].
* * * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
4(g)(1)(ii) is the same as the text of Sec.  1.1471-4T(g)(1)(ii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-4(g)(2) is 
the same as the text of Sec.  1.1471-4T(g)(2) published elsewhere in 
this issue of the Federal Register].
* * * * *
0
Par. 6. Section 1.1471-5 is amended by:
0
1. By removing paragraphs (a)(3)(ii) (b)(3)(v)(B)(3), and 
(b)(3)(vi)(B)(3).
0
2. By redesignating paragraphs (a)(3)(iii) through (a)(3)(vi) as 
paragraphs (a)(3)(ii) through (a)(3)(v) and paragraph (j) as paragraph 
(l).
0
3. By adding paragraphs (f)(1)(i)(F)(3)(vii), (f)(1)(i)(F)(3)(viii), 
(f)(2)(v), (j), and (k).
0
4. By revising paragraphs (a)(3)(i), (a)(4)(i), (b)(1)(iii)(B)(2), 
(b)(3)(iv), (b)(3)(v)(A), (b)(3)(v)(B)(1) through (2), (b)(3)(vi), (c), 
(e)(1)(v)(A), (e)(3)(ii), (e)(4)(v) Example 7 through Example 8, 
(e)(5)(i)(A)(3), (e)(5)(i)(B) introductory text, (e)(5)(i)(B)(1), 
(e)(5)(i)(C), (e)(5)(i)(D)(1)(iv) through (v), (e)(5)(iv)(B), 
(f)(1)(i)(A)(6), (f)(1)(i)(B)(1), (f)(1)(i)(B)(3), (f)(1)(i)(C)(2), 
(f)(1)(i)(D)(4) through (6), (f)(1)(i)(D)(7) introductory text, 
(f)(1)(i)(E), (f)(1)(i)(F)(1)(ii), (f)(1)(i)(F)(3)(v) through (vi), 
(f)(1)(i)(F)(5), (f)(1)(ii)(B), (f)(2) introductory text, (f)(2)(i)(B), 
(f)(2)(iii) through (iv), (f)(4)(i), (g)(3)(i)(D), and (i).
    The additions and revisions read as follows:


Sec.  1.1471-5  Definitions applicable to section 1471.

    (a) * * *
    (3) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-5(a)(3)(i) 
is the same as the text of Sec.  1.1471-5T(a)(3)(i) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (4) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-5(a)(4)(i) 
is the same as the text of Sec.  1.1471-5T(a)(4)(i) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (b) * * *
    (1) * * *
    (iii) * * *
    (B) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-
5(b)(1)(iii)(B)(2) is the same as the text of Sec.  1.1471-
5T(b)(1)(iii)(B)(2) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (3) * * *
    (iv) [The text of the proposed amendment to Sec.  1.1471-
5(b)(3)(iv) is the same as the text of Sec.  1.1471-5T(b)(3)(iv) 
published elsewhere in this issue of the Federal Register].
    (v) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
5(b)(3)(v)(A) is the same as the text of Sec.  1.1471-5T(b)(3)(v)(A) 
published elsewhere in this issue of the Federal Register].
    (B) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
5(b)(3)(v)(B)(1) is the same as the text of Sec.  1.1471-
5T(b)(3)(v)(B)(1) published elsewhere in this issue of the Federal 
Register].
    (2) [The text of the proposed amendment to Sec.  1.1471-
5(b)(3)(v)(B)(2) is the same as the text of Sec.  1.1471-
5T(b)(3)(v)(B)(2) published elsewhere in this issue of the Federal 
Register].
    (vi) [The text of the proposed amendment to Sec.  1.1471-
5(b)(3)(vi) is the same as the text of Sec.  1.1471-5T(b)(3)(vi) 
through (b)(3)(vi)(B)(2) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (c) [The text of the proposed amendment to Sec.  1.1471-5(c) is the 
same as the text of Sec.  1.1471-5T(c) published elsewhere in this 
issue of the Federal Register].
* * * * *
    (e) * * *
    (1) * * *
    (v) * * *
    (A) [The text of the proposed amendment to Sec.  1.1471-
5(e)(1)(v)(A) is the same as the text of Sec.  1.1471-5T(e)(1)(v)(A) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (3) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
5(e)(3)(ii) is the same as the text of Sec.  1.1471-5T(e)(3)(ii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (4) * * *
    (v) * * *
    Example 7. [The text of the proposed amendment to Example 7of Sec.  
1.1471-5(e)(4)(v) is the same as the text of Example 7 of Sec.  1.1471-
5T(e)(4)(v) published elsewhere in this issue of the Federal Register].
    Example 8. [The text of the proposed amendment to Example 8 of 
Sec.  1.1471-5(e)(4)(v) is the same as the text of Example 8 of Sec.  
1.1471-5T(e)(4)(v) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (5) * * *
    (i) * * *
    (A) * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(A)(3) is the same as the text of Sec.  1.1471-
5T(e)(5)(i)(A)(3) published elsewhere in this issue of the Federal 
Register].
    (B) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(B) introductory text is the same as the text of Sec.  
1.1471-5T(e)(5)(i)(B) published elsewhere in this issue of the Federal 
Register].
    (1) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(B)(1) is the same as the text of Sec.  1.1471-
5T(e)(5)(i)(B)(1) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (C) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(C) is the same as the text of Sec.  1.1471-

[[Page 12875]]

5T(e)(5)(i)(C) published elsewhere in this issue of the Federal 
Register].
    (D) * * *
    (1) * * *
    (iv) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(D)(1)(iv) is the same as the text of Sec.  1.1471-
5T(e)(5)(i)(D)(1)(iv) published elsewhere in this issue of the Federal 
Register].
    (v) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(i)(D)(1)(v) is the same as the text of Sec.  1.1471-
5T(e)(5)(i)(D)(1)(v) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (iv) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
5(e)(5)(iv)(B) is the same as the text of Sec.  1.1471-5T(e)(5)(iv)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (f) * * *
    (1) * * *
    (i) * * *
    (A) * * *
    (6) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(A)(6) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(A)(6) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (B) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(B)(1) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(B)(1) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (3) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(B)(3) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(B)(3) published elsewhere in this issue of the Federal 
Register].
    (C) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(C)(2) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(C)(2) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (D) * * *
    (4) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(D)(4) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(D)(4) published elsewhere in this issue of the Federal 
Register].
    (5) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(D)(5) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(D)(5) published elsewhere in this issue of the Federal 
Register].
    (6) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(D)(6) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(D)(6) published elsewhere in this issue of the Federal 
Register].
    (7) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(D)(7) introductory text is the same as the text of Sec.  
1.1471-5T(f)(1)(i)(D)(7) introductory text published elsewhere in this 
issue of the Federal Register].
* * * * *
    (E) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(E) is the same as the text of Sec.  1.1471-5T(f)(1)(i)(E) 
through (f)(1)(i)(E)(2) published elsewhere in this issue of the 
Federal Register].
    (F) * * *
    (1) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(F)(1)(ii) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(E)(1)(ii) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (3) * * *
    (v) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(F)(3)(v) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(F)(3)(v) published elsewhere in this issue of the Federal 
Register].
    (vi) [The text of proposed Sec.  1.1471-5(f)(1)(i)(F)(3)(vi) is the 
same as the text of Sec.  1.1471-5T(f)(1)(i)(F)(3)(vi) published 
elsewhere in this issue of the Federal Register].
    (vii) [The text of proposed Sec.  1.1471-5(f)(1)(i)(F)(3)(vii) is 
the same as the text of Sec.  1.1471-5T(f)(1)(i)(F)(3)(vii) published 
elsewhere in this issue of the Federal Register].
    (viii) [The text of proposed Sec.  1.1471-5(f)(1)(i)(F)(3)(viii) is 
the same as the text of Sec.  1.1471-5T(f)(1)(i)(F)(3)(viii) published 
elsewhere in this issue of the Federal Register].
* * * * *
    (5) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(i)(F)(5) is the same as the text of Sec.  1.1471-
5T(f)(1)(i)(F)(5) published elsewhere in this issue of the Federal 
Register].
    (ii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
5(f)(1)(ii)(B) is the same as the text of Sec.  1.1471-5T(f)(1)(ii)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-5(f)(2) 
introductory text is the same as the text of Sec.  1.1471-5T(f)(2) 
published elsewhere in this issue of the Federal Register].
    (i) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
5(f)(2)(i)(B) is the same as the text of Sec.  1.1471-5T(f)(2)(i)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (iii) [The text of the proposed amendment to Sec.  1.1471-
5(f)(2)(iii) is the same as the text of Sec.  1.1471-5T(f)(2)(iii) 
through (f)(2)(iii)(E) published elsewhere in this issue of the Federal 
Register].
    (iv) [The text of the proposed amendment to Sec.  1.1471-
5(f)(2)(iv) is the same as the text of Sec.  1.1471-5T(f)(2)(iv) 
through (f)(2)(iv)(F) published elsewhere in this issue of the Federal 
Register].
    (v) [The text of proposed Sec.  1.1471-5(f)(2)(v) is the same as 
the text of Sec.  1.1471-5T(f)(2)(v) published elsewhere in this issue 
of the Federal Register].
* * * * *
    (4) * * *
    (i) [The text of the proposed amendment to Sec.  1.1471-5(f)(4)(i) 
is the same as the text of Sec.  1.1471-5T(f)(4)(i) published elsewhere 
in this issue of the Federal Register].
* * * * *
    (g) * * *
    (3) * * *
    (i) * * *
    (D) [The text of the proposed amendment to Sec.  1.1471-
5(g)(3)(i)(D) is the same as the text of Sec.  1.1471-5T(g)(3)(i)(D) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (i) [The text of proposed Sec.  1.1471-5(i) is the same as the text 
of Sec.  1.1471-5T(i) through (i)(10) published elsewhere in this issue 
of the Federal Register].
    (j) [The text of proposed Sec.  1.1471-5(j) is the same as the text 
of Sec.  1.1471-5T(j) published elsewhere in this issue of the Federal 
Register].
    (k) [The text of proposed Sec.  1.1471-5(k) is the same as the text 
of Sec.  1.1471-5T(k) published elsewhere in this issue of the Federal 
Register].
* * * * *
0
Par. 7. Section 1.1471-6 is amending by revising paragraphs (d)(1), 
(d)(4), (f)(2)(iii)(B) through (C), (f)(3)(ii) through (iii), (f)(5) 
through (6), (g), and (h)(2) to read as follows:


Sec.  1.1471-6  Payments beneficially owned by exempt beneficial 
owners.

* * * * *
    (d) * * *
    (1) [The text of the proposed amendment to Sec.  1.1471-6(d)(1) is 
the same as the text of Sec.  1.1471-6T(d)(1) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (4) [The text of the proposed amendment to Sec.  1.1471-6(d)(4) is 
the

[[Page 12876]]

same as the text of Sec.  1.1471-6T(d)(4) published elsewhere in this 
issue of the Federal Register].
* * * * *
    (f) * * *
    (2) * * *
    (iii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1471-
6(f)(2)(iii)(B) is the same as the text of Sec.  1.1471-
6T(f)(2)(iii)(B) published elsewhere in this issue of the Federal 
Register].
    (C) [The text of the proposed amendment to Sec.  1.1471-
6(f)(2)(iii)(C) is the same as the text of Sec.  1.1471-
6T(f)(2)(iii)(C) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (3) * * *
    (ii) [The text of the proposed amendment to Sec.  1.1471-
6(f)(3)(ii) is the same as the text of Sec.  1.1471-6T(f)(3)(ii) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of the proposed amendment to Sec.  1.1471-
6(f)(3)(iii) is the same as the text of Sec.  1.1471-6T(f)(3)(iii) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (5) [The text of the proposed amendment to Sec.  1.1471-6(f)(5) is 
the same as the text of Sec.  1.1471-6T(f)(5) published elsewhere in 
this issue of the Federal Register].
    (6) [The text of the proposed amendment to Sec.  1.1471-6(f)(6) is 
the same as the text of Sec.  1.1471-6T(f)(6) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (g) [The text of the proposed amendment to Sec.  1.1471-6(g) is the 
same as the text of Sec.  1.1471-6T(g) published elsewhere in this 
issue of the Federal Register].
    (h) * * *
    (2) [The text of the proposed amendment to Sec.  1.1471-6(h)(2) is 
the same as the text of Sec.  1.1471-6T(h)(2) introductory text through 
(h)(2)(iii) published elsewhere in this issue of the Federal Register].
* * * * *
0
Par. 8. Section 1.1472-1 is amended by:
0
1. By redesignating paragraph (f) as paragraph (h).
0
2. By adding paragraphs (c)(1)(vi) through (vii), (c)(3) through (5), 
(f), and (g).
0
3. By revising paragraphs (b)(1) introductory text, (b)(2), (c)(1) 
introductory text, (c)(1)(i) introductory text, (c)(1)(ii) through 
(iii), (c)(1)(iv) introductory text, (c)(1)(iv)(C), (c)(1)(v), (c)(2), 
and (d)(1) through (2).
    The additions and revisions read as follows:


Sec.  1.1472-1  Withholding on NFFEs.

* * * * *
    (b) * * *
    (1) [The text of the proposed amendment to Sec.  1.1472-1(b)(1) is 
the same as the text of Sec.  1.1472-1T(b)(1) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (2) [The text of the proposed amendment to Sec.  1.1472-1(b)(2) is 
the same as the text of Sec.  1.1472-1T(b)(2) published elsewhere in 
this issue of the Federal Register].
    (c) * * *
    (1) [The text of the proposed amendment to Sec.  1.1472-1(c)(1) is 
the same as the text of Sec.  1.1472-1T(c)(1) published elsewhere in 
this issue of the Federal Register].
    (i) [The text of the proposed amendment to Sec.  1.1472-1(c)(1)(i) 
introductory text is the same as the text of Sec.  1.1472-1T(c)(1)(i) 
published elsewhere in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1472-
1(c)(1)(ii) is the same as the text of Sec.  1.1472-1T(c)(1)(ii) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of the proposed amendment to Sec.  1.1472-
1(c)(1)(iii) is the same as the text of Sec.  1.1472-1T(c)(1)(iii) 
published elsewhere in this issue of the Federal Register].
    (iv) [The text of the proposed amendment to Sec.  1.1472-
1(c)(1)(iv) introductory text is the same as the text of Sec.  1.1472-
1T(c)(1)(iv) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (C) [The text of the proposed amendment to Sec.  1.1472-
1(c)(1)(iv)(C) is the same as the text of Sec.  1.1472-1T(c)(1)(iv)(C) 
published elsewhere in this issue of the Federal Register].
    (v) [The text of the proposed amendment to Sec.  1.1472-1(c)(1)(v) 
is the same as the text of Sec.  1.1472-1T(c)(1)(v) published elsewhere 
in this issue of the Federal Register].
    (vi) [The text of proposed Sec.  1.1472-1(c)(1)(vi) is the same as 
the text of Sec.  1.1472-1T(c)(1)(vi) published elsewhere in this issue 
of the Federal Register].
    (vii) [The text of proposed Sec.  1.1472-1(c)(1)(vii) is the same 
as the text of Sec.  1.1472-1T(c)(1)(vii) published elsewhere in this 
issue of the Federal Register].
    (2) [The text of the proposed amendment to Sec.  1.1472-1(c)(2) is 
the same as the text of Sec.  1.1472-1T(c)(2) published elsewhere in 
this issue of the Federal Register].
    (3) [The text of proposed Sec.  1.1472-1(c)(3) is the same as the 
text of Sec.  1.1472-1T(c)(3) published elsewhere in this issue of the 
Federal Register].
    (4) [The text of proposed Sec.  1.1472-1(c)(4) is the same as the 
text of Sec.  1.1472-1T(c)(4) published elsewhere in this issue of the 
Federal Register].
    (5) [The text of proposed Sec.  1.1472-1(c)(5) is the same as the 
text of Sec.  1.1472-1T(c)(5) published elsewhere in this issue of the 
Federal Register].
    (d) * * *
    (1) [The text of the proposed amendment to Sec.  1.1472-1(d)(1) is 
the same as the text of Sec.  1.1472-1T(d)(1) published elsewhere in 
this issue of the Federal Register].
    (2) [The text of the proposed amendment to Sec.  1.1472-1(d)(2) is 
the same as the text of Sec.  1.1472-1T(d)(2) published elsewhere in 
this issue of the Federal Register].
* * * * *
    (f) [The text of proposed Sec.  1.1472-1(f) is the same as the text 
of Sec.  1.1472-1T(f) published elsewhere in this issue of the Federal 
Register].
    (g) [The text of proposed Sec.  1.1472-1(g) is the same as the text 
of Sec.  1.1472-1T(g) published elsewhere in this issue of the Federal 
Register].
* * * * *
0
Par. 9. Section 1.1473-1 is amended by:
0
1. Adding new paragraph (a)(4)(vii).
0
2. Revising paragraphs (a)(2)(vi), (a)(3)(iii)(B)(4), (a)(4)(vi), 
(a)(5)(i) through (vi), and (b)(2)(v).
    The addition and revisions read as follows:


Sec.  1.1473-1  Section 1473 definitions.

    (a) * * *
    (2) * * *
    (vi) [The text of the proposed amendment to Sec.  1.1473-
1(a)(2)(vi) is the same as the text of Sec.  1.1473-1T(a)(2)(vi) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (3) * * *
    (iii) * * *
    (B) * * *
    (4) [The text of the proposed amendment to Sec.  1.1473-
1(a)(3)(iii)(B)(4) is the same as the text of Sec.  1.1473-
1T(a)(3)(iii)(B)(4) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (4) * * *
    (vi) [The text of the proposed amendment to Sec.  1.1473-
1(a)(4)(vi) is the same as the text of Sec.  1.1473-1T(a)(4)(vi) 
published elsewhere in this issue of the Federal Register].
    (vii) [The text of proposed Sec.  1.1473-1(a)(4)(vii) is the same 
as the text of

[[Page 12877]]

Sec.  1.1473-1T(a)(4)(vii) published elsewhere in this issue of the 
Federal Register].
    (5) * * *
    (i) [The text of the proposed amendment to Sec.  1.1473-1(a)(5)(i) 
is the same as the text of Sec.  1.1473-1T(a)(5)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1473-
1(a)(5)(ii) is the same as the text of Sec.  1.1473-1T(a)(5)(ii) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of the proposed amendment to Sec.  1.1473-
1(a)(5)(iii) is the same as the text of Sec.  1.1473-1T(a)(5)(iii) 
published elsewhere in this issue of the Federal Register].
    (iv) [The text of the proposed amendment to Sec.  1.1473-
1(a)(5)(iv) is the same as the text of Sec.  1.1473-1T(a)(5)(iv) 
published elsewhere in this issue of the Federal Register].
    (v) [The text of the proposed amendment to Sec.  1.1473-1(a)(5)(v) 
is the same as the text of Sec.  1.1473-1T(a)(5)(v) published elsewhere 
in this issue of the Federal Register].
    (vi) [The text of the proposed amendment to Sec.  1.1473-
1(a)(5)(vi) is the same as the text of Sec.  1.1473-1T(a)(5)(vi) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (b) * * *
    (2) * * *
    (v) [The text of the proposed amendment to Sec.  1.1473-1(b)(2)(v) 
is the same as the text of Sec.  1.1473-1T(b)(2)(v) published elsewhere 
in this issue of the Federal Register].
* * * * *
0
Par. 10. Section 1.1474-1 is amended:
0
1. By removing paragraphs (d)(1)(ii)(A)(1)(ix), (d)(3)(iii), and 
(i)(1)(iv) through (v).
0
2. By redesignating paragraphs (d)(1)(ii)(A)(1)(x) through (xii) as 
(d)(1)(ii)(A)(1)(ix) through (xi), and paragraphs (d)(3)(iv) through 
(x) as (d)(3)(iii) through (ix).
0
3. By revising paragraphs (d)(1)(i), (d)(1)(ii)(A)(1)(viii) through 
(ix), (d)(1)(ii)(B)(1)(i), (d)(1)(ii)(B)(1)(vi) through (vii), 
(d)(1)(ii)(B)(1)(ix), (d)(2)(i), (d)(4)(i)(B), (d)(4)(i)(E), 
(d)(4)(ii)(B), (d)(4)(iii), (i)(1) introductory text, (i)(1)(i) through 
(iii), (i)(2) introductory text, and (i)(2)(iii).
    The additions and revisions read as follows:


Sec.  1.1474-1  Liability for withheld tax and withholding agent 
reporting.

* * * * *
    (d) * * *
    (1) * * *
    (i) [The text of the proposed amendment to Sec.  1.1474-1(d)(1)(i) 
is the same as the text of Sec.  1.1474-1T(d)(1)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) * * *
    (A) * * *
    (1) * * *
    (viii) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(A)(1)(viii) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(A)(1)(viii) published elsewhere in this issue of the 
Federal Register].
    (ix) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(A)(1)(ix) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(A)(1)(ix) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (B) * * *
    (1) * * *
    (i) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(B)(1)(i) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(B)(1)(i) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (vi) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(B)(1)(vi) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(B)(1)(vi) published elsewhere in this issue of the Federal 
Register].
    (vii) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(B)(1)(vii) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(B)(1)(vii) published elsewhere in this issue of the 
Federal Register].
* * * * *
    (ix) [The text of the proposed amendment to Sec.  1.1474-
1(d)(1)(ii)(B)(1)(ix) is the same as the text of Sec.  1.1474-
1T(d)(1)(ii)(B)(1)(ix) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (2) * * *
    (i) [The text of the proposed amendment to Sec.  1.1474-1(d)(2)(i) 
is the same as the text of Sec.  1.1474-1T(d)(2)(i) through 
(d)(2)(i)(C) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (4) * * *
    (i) * * *
    (B) [The text of the proposed amendment to Sec.  1.1474-
1(d)(4)(i)(B) is the same as the text of Sec.  1.1474-1T(d)(4)(i)(B) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (E) [The text of the proposed amendment to Sec.  1.1474-
1(d)(4)(i)(E) is the same as the text of Sec.  1.1474-1T(d)(4)(i)(E) 
published elsewhere in this issue of the Federal Register].
    (ii) * * *
    (B) [The text of the proposed amendment to Sec.  1.1474-
1(d)(4)(ii)(B) is the same as the text of Sec.  1.1474-1T(d)(4)(ii)(B) 
published elsewhere in this issue of the Federal Register].
    (C) [The text of the proposed amendment to Sec.  1.1474-
1(d)(4)(ii)(C) is the same as the text of Sec.  1.1474-1T(d)(4)(ii)(C) 
published elsewhere in this issue of the Federal Register].
    (iii) * * *
    [The text of the proposed amendment to Sec.  1.1474-1(d)(4)(iii) is 
the same as the text of Sec.  1.1474-1T(d)(4)(iii) through 
(d)(4)(iii)(C) published elsewhere in this issue of the Federal 
Register].
* * * * *
    (i) * * *
    (1) [The text of the proposed amendment to Sec.  1.1474-1(i)(1) 
introductory text is the same as the text of Sec.  1.1474-1T(i)(1) 
published elsewhere in this issue of the Federal Register].
    (i) [The text of the proposed amendment to Sec.  1.1474-1(i)(1)(i) 
is the same as the text of Sec.  1.1474-1T(i)(1)(i) published elsewhere 
in this issue of the Federal Register].
    (ii) [The text of the proposed amendment to Sec.  1.1474-
1(i)(1)(ii) is the same as the text of Sec.  1.1474-1T(i)(1)(ii) 
published elsewhere in this issue of the Federal Register].
    (iii) [The text of the proposed amendment to Sec.  1.1474-
1(i)(1)(iii) is the same as the text of Sec.  1.1474-1T(i)(1)(iii) 
published elsewhere in this issue of the Federal Register].
    (2) [The text of the proposed amendment to Sec.  1.1474-1(i)(2) 
introductory text is the same as the text of Sec.  1.1474-1T(i)(2) 
published elsewhere in this issue of the Federal Register].
* * * * *
    (iii) [The text of the proposed amendment to Sec.  1.1474-
1(i)(2)(iii) is the same as the text of Sec.  1.1474-1T(i)(2)(iii) 
published elsewhere in this issue of the Federal Register].
* * * * *
0
Par. 11. Section 1.1474-6 is amended by:
0
1. Revising paragraph (b)(1).
0
2. Redesignating paragraph (f) as paragraph (g).
0
3. Adding new paragraph (f).
    The revision and addition read as follows:


Sec.  1.1474-6  Coordination of chapter 4 with other withholding 
provisions.

* * * * *
    (b) * * *
    (1) [The text of the proposed amendment to Sec.  1.1474-6(b)(1) is 
the

[[Page 12878]]

same as the text of Sec.  1.1474-6T(b)(1) published elsewhere in this 
issue of the Federal Register].
* * * * *
    (f) [The text of proposed Sec.  1.1474-6(f) is the same as the text 
of Sec.  1.1474-6T(f) published elsewhere in this issue of the Federal 
Register].
* * * * *

John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2014-03960 Filed 2-28-14; 4:15 pm]
BILLING CODE 4830-01-P