Disallowance of Partnership Loss Transfers, Mandatory Basis Adjustments, Basis Reduction in Stock of a Corporate Partner, Modification of Basis Allocation Rules for Substituted Basis Transactions, Miscellaneous Provisions; Correction, 21163-21164 [2014-08360]
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Federal Register / Vol. 79, No. 72 / Tuesday, April 15, 2014 / Proposed Rules
of the cockpit windshield center-post,
including a general visual inspection for any
damage (cracks, dents, scratches) of the
specified lower eyelet fitting, in accordance
with Part II of the Accomplishment
Instructions of EMBRAER Service Bulletin
145LEG–53–A032, Revision 01, dated
September 24, 2013. If any damage is found
during the general visual inspection, before
further flight repair using a method approved
by the Manager, International Branch, ANM–
116, Transport Airplane Directorate, FAA; or
ˆ
The Agencia Nacional de Aviacao Civil
¸˜
(ANAC) (or its delegated agent, or the Design
Approval Holder (DAH) with ANAC design
organization approval). For a repair method
to be approved, the repair approval must
specifically refer to this AD. The
modification terminates the repetitive
inspections required by paragraph (g) of this
AD.
(1) For airplanes identified as Group 1 in
EMBRAER Service Bulletin 145LEG–53–
A032, Revision 01, dated September 24,
2013, on which the actions specified in
EMBRAER Service Bulletin 145LEG–53–
0021, has been done: Do the modification
before the accumulation of 3,000 flight cycles
after doing the actions specified in
EMBRAER Service Bulletin 145LEG–53–
0021, or within 300 flight cycles after the
effective date of this AD, whichever occurs
later.
(2) For airplanes identified as Group 2 in
EMBRAER Service Bulletin 145LEG–53–
A032, Revision 01, dated September 24,
2013: Do the modification before the
accumulation of 3,000 total flight cycles, or
within 300 flight cycles after the effective
date of this AD, whichever occurs later.
ehiers on DSK2VPTVN1PROD with PROPOSALS-1
(i) Credit for Previous Actions
This paragraph provides credit for actions
required by paragraphs (g) and (h) of this AD,
if those actions were performed before the
effective date of this AD using EMBRAER
Service Bulletin 145LEG–53–A032, dated
September 20, 2013, which is not
incorporated by reference in this AD.
(j) Other FAA AD Provisions
The following provisions also apply to this
AD:
(1) Alternative Methods of Compliance
(AMOCs): The Manager, International
Branch, ANM–116, FAA, has the authority to
approve AMOCs for this AD, if requested
using the procedures found in 14 CFR 39.19.
In accordance with 14 CFR 39.19, send your
request to your principal inspector or local
Flight Standards District Office, as
appropriate. If sending information directly
to the International Branch, send it to ATTN:
Todd Thompson, Aerospace Engineer,
International Branch, ANM–116, Transport
Airplane Directorate, FAA, 1601 Lind
Avenue SW., Renton, Washington 98057–
3356; telephone (425) 227–1175; fax (425)
227–1149. Information may be emailed to: 9ANM-116-AMOC-REQUESTS@faa.gov.
Before using any approved AMOC, notify
your appropriate principal inspector, or
lacking a principal inspector, the manager of
the local flight standards district office/
certificate holding district office. The AMOC
approval letter must specifically reference
this AD.
VerDate Mar<15>2010
14:49 Apr 14, 2014
Jkt 232001
(2) Airworthy Product: For any requirement
in this AD to obtain corrective actions from
a manufacturer, use these actions if they are
FAA-approved. Corrective actions are
considered FAA-approved if they were
approved by the State of Design Authority (or
its delegated agent, or the DAH with a State
of Design Authority’s design organization
approval). For a repair method to be
approved, the repair approval must
specifically refer to this AD. You are required
to ensure the product is airworthy before it
is returned to service.
(k) Related Information
(1) Refer to Mandatory Continuing
Airworthiness Information (MCAI) Brazilian
Airworthiness Directive 2013–10–02, dated
October 23, 2013, for related information.
This MCAI may be found in the AD docket
on the Internet at https://www.regulations.gov
by searching for and locating it in Docket No.
FAA–2014–0234.
(2) For service information identified in
this AD, contact Empresa Brasileira de
Aeronautica S.A. (EMBRAER), Technical
Publications Section (PC 060), Av. Brigadeiro
˜
Faria Lima, 2170—Putim—12227–901 Sao
Jose dos Campos—SP—BRASIL; telephone
+55 12 3927–5852 or +55 12 3309–0732; fax
+55 12 3927–7546; email distrib@
embraer.com.br; Internet https://
www.flyembraer.com. You may view this
service information at the FAA, Transport
Airplane Directorate, 1601 Lind Avenue SW.,
Renton, WA. For information on the
availability of this material at the FAA, call
425–227–1221.
Issued in Renton, Washington, on April 1,
2014.
Michael Kaszycki,
Acting Manager, Transport Airplane
Directorate, Aircraft Certification Service.
[FR Doc. 2014–08460 Filed 4–14–14; 8:45 am]
BILLING CODE 4910–13–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–144468–05]
RIN 1545–BE98
Disallowance of Partnership Loss
Transfers, Mandatory Basis
Adjustments, Basis Reduction in Stock
of a Corporate Partner, Modification of
Basis Allocation Rules for Substituted
Basis Transactions, Miscellaneous
Provisions; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Correction to a notice of
proposed rulemaking and notice of
public hearing.
AGENCY:
This document contains
corrections to a notice of proposed
rulemaking and notice of public hearing
SUMMARY:
PO 00000
Frm 00011
Fmt 4702
Sfmt 4702
21163
(REG–144468–05) that was published in
the Federal Register on Thursday,
January 16, 2014. The proposed rules
provide guidance on certain provisions
of the American Jobs Creation Act of
2004 and conform the regulations to
statutory changes in the Taxpayer Relief
Act of 1997.
DATES: Written or electronic comments
and requests for a public hearing for the
notice of proposed rulemaking
published at 79 FR 3042, January 16,
2014, are still being accepted and must
be received by April 16, 2014.
FOR FURTHER INFORMATION CONTACT:
Benjamin Weaver or Wendy Kribell at
(202) 317–6850 (not a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking
and notice of public hearing (REG–
144468–05) that is the subject of these
corrections is under sections 704, 732,
734, 743, 755, and 1502 of the Internal
Revenue Code.
Need for Correction
As published, the notice of proposed
rulemaking and notice of public hearing
(REG–144468–05) contains errors that
may prove to be misleading and are in
need of clarification.
Correction of Publication
Accordingly, the notice of proposed
rulemaking and notice of public hearing
(REG–144468–05), that was the subject
of FR Doc. 2014–00649, is corrected as
follows:
1. On page 3042, in the preamble,
third column, thirty-third line from the
top of the page, the language ‘‘3,600.’’ is
corrected to read ‘‘3,600 hours.’’.
2. On page 3042, in the preamble,
third column, fortieth line from the top
of the page, the language ‘‘burden:
2,700.’’ is corrected to read ‘‘burden:
2,700 hours.’’.
3. On page 3046, in the preamble,
second column, twenty-fifth line of the
first full paragraph, the language
‘‘1(b)(2)(iv)(f) (‘‘reverse section 704(c)’’
is corrected to read ‘‘1(b)(2)(iv)(f) or
§ 1.704–1(b)(2)(iv)(s) (‘‘reverse section
704(c)’’.
4. On page 3052, in the preamble,
second column, tenth line from the
bottom of the page, the language
‘‘Questions have been raised whether
the’’ is corrected to read ‘‘Questions
have been raised regarding whether
the’’.
5. On page 3054, in the preamble,
second column, seventh line from the
top of the page, the language ‘‘by
differences in the property’s adjusted’’
is corrected to read ‘‘by decreases in the
E:\FR\FM\15APP1.SGM
15APP1
21164
Federal Register / Vol. 79, No. 72 / Tuesday, April 15, 2014 / Proposed Rules
difference between the property’s
adjusted’’.
6. On page 3054, in the preamble,
second column, sixteenth line from the
top of the page, the language
‘‘1(b)(2)(iv)(f). Thus, for example,
under’’ is corrected to read
‘‘1(b)(2)(iv)(f) or § 1.704–1(b)(2)(iv)(s).
Thus, for example, under’’.
ehiers on DSK2VPTVN1PROD with PROPOSALS-1
§ 1.704–3
[Corrected]
7. On page 3055, third column, the
second sentence of paragraph (a)(3)(ii)
should read ‘‘The built-in gain is
thereafter reduced by decreases in the
difference between the property’s book
value and adjusted tax basis (other than
decreases to the property’s book value
pursuant to § 1.704–1(b)(2)(iv)(f) or
§ 1.704–1(b)(2)(iv)(s)).’’.
8. On page 3056, first column, the
fourth sentence of paragraph (a)(3)(ii)
should read ‘‘The built-in loss is
thereafter reduced by decreases in the
difference between the property’s
adjusted tax basis and book value (other
than increases to the property’s book
value pursuant to § 1.704–1(b)(2)(iv)(f)
or § 1.704–1(b)(2)(iv)(s)).’’.
9. On page 3056, first column, the first
sentence of paragraph (a)(6)(i) should
read ‘‘The principles of this section
apply with respect to property for which
differences between book value and
adjusted tax basis are created when a
partnership revalues partnership
property pursuant to § 1.704–
1(b)(2)(iv)(f) or § 1.704–1(b)(2)(iv)(s)
(reverse section 704(c) allocations).’’.
10. On page 3056, second column, the
second sentence of paragraph (f)(2)(i)
should read ‘‘Section 704(c)(1)(C)
property does not include a § 1.752–7
liability (within the meaning of § 1.752–
7(b)(3)) or property for which
differences between book value and
adjusted tax basis are created when a
partnership revalues property pursuant
to § 1.704–1(b)(2)(iv)(f) or § 1.704–
1(b)(2)(iv)(s).’’.
11. On page 3057, second column, the
third sentence of paragraph
(f)(3)(iii)(B)(1) should read ‘‘Regardless
of whether a section 754 election is in
effect or a substantial built in loss exists
with respect to the transfer, the amount
of any section 704(c)(1)(C) basis
adjustment with respect to section
704(c)(1)(C) property to which the
transferee succeeds shall be decreased
by the amount of any negative section
743(b) adjustment that would be
allocated to the section 704(c)(1)(C)
property pursuant to the provisions of
§ 1.755–1 if the partnership had a
section 754 election in effect upon the
transfer.’’.
VerDate Mar<15>2010
14:49 Apr 14, 2014
Jkt 232001
§ 1.734–2
[Corrected]
12. On page 3062, third column, the
first sentence of paragraph (c)(3)
Example 2. (ii) should read ‘‘A is unable
to take into account A’s section
704(c)(1)(C) basis adjustment in
Property 1 upon the distribution of the
cash as described in paragraph (c)(2) of
this section because A cannot increase
the basis of cash under § 1.704–
3(f)(3)(v)(C).’’.
§ 1.755–1
[Corrected]
13. On page 3068, third column,
paragraph (b)(5)(iv) Example 4. (i)
should read ‘‘A is a one-third partner in
LTP. The three partners in LTP have
equal interests in the capital and profits
of LTP. LTP has two assets: accounts
receivable with an adjusted basis of
$300 and a fair market value of $240
and a nondepreciable capital asset with
an adjusted basis of $60 and a fair
market value of $240. A contributes its
interest in LTP to UTP in a transaction
described in section 721. At the time of
the transfer, A’s basis in its LTP interest
is $90. Under section 723, UTP’s basis
in its interest in LTP is $90. LTP makes
an election under section 754 in
connection with the transfer.’’.
14. On page 3068, third column, the
first sentence of paragraph (b)(5)(iv)
Example 4. (ii) should read ‘‘The
amount of the basis adjustment under
section 743(b) is the difference between
UTP’s $90 basis in its LTP interest and
UTP’s share of the adjusted basis to LTP
of LTP’s property.’’
15. On page 3068, third column,
paragraph (e)(1)(A) is redesignated as
paragraph (e)(1)(i).
16. On page 3069, first column,
paragraph (e)(1)(B) is redesignated as
paragraph (e)(1)(ii).
17. On page 3069, first column,
paragraph (e)(2), the language ‘‘(e)(1)(B)
’’should read ‘‘(e)(1)(ii)’’ wherever it
appears.
18. On page 3069, first column,
paragraph ‘‘(3) Example.’’ Is corrected to
read ‘‘(3) Example.’’.
19. On page 3069, first and second
column, paragraph (e)(3) should read
‘‘Example. A, B, and C are equal
partners in PRS, a partnership. C is a
corporation. The adjusted basis and fair
market value for A’s interests in PRS is
$100. PRS owns Capital Asset 1 with an
adjusted basis of $0 and a fair market
value of $100, Capital Asset 2 with an
adjusted basis of $150 and a fair market
value of $50, and stock in Corp, a
corporation that is related to C under
section 267(b), with an adjusted basis of
$250 and fair market value of $150. PRS
has a section 754 election in effect. PRS
distributes Capital Asset 1 to A in
liquidation of A’s interest in PRS. PRS
PO 00000
Frm 00012
Fmt 4702
Sfmt 4702
will reduce the basis of its remaining
assets under section 734(b) by $100, to
be allocated under section 755. Pursuant
to the general rule of paragraph (c) of
this section, PRS would reduce the basis
of Capital Asset 2 by $50 and the stock
of Corp by $50. However, pursuant to
paragraph (e)(1)(i) of this section, the
basis of the Corp stock is not adjusted.
Thus, the basis of Capital Asset 2 is
reduced by $100 from $150 to $50.’’.
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2014–08360 Filed 4–14–14; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF LABOR
Occupational Safety and Health
Administration
29 CFR Part 1926
[Docket ID–OSHA–2007–0066]
RIN 1218–AC86
Cranes and Derricks in Construction:
Operator Certification
Occupational Safety and Health
Administration (OSHA), U.S.
Department of Labor.
ACTION: Notice of informal public
hearing.
AGENCY:
This notice schedules an
informal public hearing on OSHA’s
proposed extension of the craneoperator certification deadline and the
separate existing employer duty to
ensure that their crane operators are
competent. The Agency proposed threeyear extensions for both, from
November 10, 2014, to November 10,
2017.
SUMMARY:
Informal public hearing: The
informal public hearing will be held on
Monday, May 19, 2014, at 9:30 a.m. in
the auditorium of the U.S. Department
of Labor, 200 Constitution Avenue NW.,
Washington, DC 20210.
Notice of intention to appear: Each
person who wishes to testify at the
hearing must submit a notice of
intention to appear by April 25, 2014.
Each person who files a notice of
intention to appear may submit a
written copy of additional comments to
the record before or during the hearing
for inclusion in the hearing record.
Organizations may submit a single
notice of intention to appear regarding
multiple members of that organization,
but the notice must list the name,
occupational title, and position of each
DATES:
E:\FR\FM\15APP1.SGM
15APP1
]]>Agencies
[Federal Register Volume 79, Number 72 (Tuesday, April 15, 2014)]
[Proposed Rules]
[Pages 21163-21164]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-08360]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-144468-05]
RIN 1545-BE98
Disallowance of Partnership Loss Transfers, Mandatory Basis
Adjustments, Basis Reduction in Stock of a Corporate Partner,
Modification of Basis Allocation Rules for Substituted Basis
Transactions, Miscellaneous Provisions; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correction to a notice of proposed rulemaking and notice of
public hearing.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to a notice of proposed
rulemaking and notice of public hearing (REG-144468-05) that was
published in the Federal Register on Thursday, January 16, 2014. The
proposed rules provide guidance on certain provisions of the American
Jobs Creation Act of 2004 and conform the regulations to statutory
changes in the Taxpayer Relief Act of 1997.
DATES: Written or electronic comments and requests for a public hearing
for the notice of proposed rulemaking published at 79 FR 3042, January
16, 2014, are still being accepted and must be received by April 16,
2014.
FOR FURTHER INFORMATION CONTACT: Benjamin Weaver or Wendy Kribell at
(202) 317-6850 (not a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking and notice of public hearing
(REG-144468-05) that is the subject of these corrections is under
sections 704, 732, 734, 743, 755, and 1502 of the Internal Revenue
Code.
Need for Correction
As published, the notice of proposed rulemaking and notice of
public hearing (REG-144468-05) contains errors that may prove to be
misleading and are in need of clarification.
Correction of Publication
Accordingly, the notice of proposed rulemaking and notice of public
hearing (REG-144468-05), that was the subject of FR Doc. 2014-00649, is
corrected as follows:
1. On page 3042, in the preamble, third column, thirty-third line
from the top of the page, the language ``3,600.'' is corrected to read
``3,600 hours.''.
2. On page 3042, in the preamble, third column, fortieth line from
the top of the page, the language ``burden: 2,700.'' is corrected to
read ``burden: 2,700 hours.''.
3. On page 3046, in the preamble, second column, twenty-fifth line
of the first full paragraph, the language ``1(b)(2)(iv)(f) (``reverse
section 704(c)'' is corrected to read ``1(b)(2)(iv)(f) or Sec. 1.704-
1(b)(2)(iv)(s) (``reverse section 704(c)''.
4. On page 3052, in the preamble, second column, tenth line from
the bottom of the page, the language ``Questions have been raised
whether the'' is corrected to read ``Questions have been raised
regarding whether the''.
5. On page 3054, in the preamble, second column, seventh line from
the top of the page, the language ``by differences in the property's
adjusted'' is corrected to read ``by decreases in the
[[Page 21164]]
difference between the property's adjusted''.
6. On page 3054, in the preamble, second column, sixteenth line
from the top of the page, the language ``1(b)(2)(iv)(f). Thus, for
example, under'' is corrected to read ``1(b)(2)(iv)(f) or Sec. 1.704-
1(b)(2)(iv)(s). Thus, for example, under''.
Sec. 1.704-3 [Corrected]
7. On page 3055, third column, the second sentence of paragraph
(a)(3)(ii) should read ``The built-in gain is thereafter reduced by
decreases in the difference between the property's book value and
adjusted tax basis (other than decreases to the property's book value
pursuant to Sec. 1.704-1(b)(2)(iv)(f) or Sec. 1.704-
1(b)(2)(iv)(s)).''.
8. On page 3056, first column, the fourth sentence of paragraph
(a)(3)(ii) should read ``The built-in loss is thereafter reduced by
decreases in the difference between the property's adjusted tax basis
and book value (other than increases to the property's book value
pursuant to Sec. 1.704-1(b)(2)(iv)(f) or Sec. 1.704-
1(b)(2)(iv)(s)).''.
9. On page 3056, first column, the first sentence of paragraph
(a)(6)(i) should read ``The principles of this section apply with
respect to property for which differences between book value and
adjusted tax basis are created when a partnership revalues partnership
property pursuant to Sec. 1.704-1(b)(2)(iv)(f) or Sec. 1.704-
1(b)(2)(iv)(s) (reverse section 704(c) allocations).''.
10. On page 3056, second column, the second sentence of paragraph
(f)(2)(i) should read ``Section 704(c)(1)(C) property does not include
a Sec. 1.752-7 liability (within the meaning of Sec. 1.752-7(b)(3))
or property for which differences between book value and adjusted tax
basis are created when a partnership revalues property pursuant to
Sec. 1.704-1(b)(2)(iv)(f) or Sec. 1.704-1(b)(2)(iv)(s).''.
11. On page 3057, second column, the third sentence of paragraph
(f)(3)(iii)(B)(1) should read ``Regardless of whether a section 754
election is in effect or a substantial built in loss exists with
respect to the transfer, the amount of any section 704(c)(1)(C) basis
adjustment with respect to section 704(c)(1)(C) property to which the
transferee succeeds shall be decreased by the amount of any negative
section 743(b) adjustment that would be allocated to the section
704(c)(1)(C) property pursuant to the provisions of Sec. 1.755-1 if
the partnership had a section 754 election in effect upon the
transfer.''.
Sec. 1.734-2 [Corrected]
12. On page 3062, third column, the first sentence of paragraph
(c)(3) Example 2. (ii) should read ``A is unable to take into account
A's section 704(c)(1)(C) basis adjustment in Property 1 upon the
distribution of the cash as described in paragraph (c)(2) of this
section because A cannot increase the basis of cash under Sec. 1.704-
3(f)(3)(v)(C).''.
Sec. 1.755-1 [Corrected]
13. On page 3068, third column, paragraph (b)(5)(iv) Example 4. (i)
should read ``A is a one-third partner in LTP. The three partners in
LTP have equal interests in the capital and profits of LTP. LTP has two
assets: accounts receivable with an adjusted basis of $300 and a fair
market value of $240 and a nondepreciable capital asset with an
adjusted basis of $60 and a fair market value of $240. A contributes
its interest in LTP to UTP in a transaction described in section 721.
At the time of the transfer, A's basis in its LTP interest is $90.
Under section 723, UTP's basis in its interest in LTP is $90. LTP makes
an election under section 754 in connection with the transfer.''.
14. On page 3068, third column, the first sentence of paragraph
(b)(5)(iv) Example 4. (ii) should read ``The amount of the basis
adjustment under section 743(b) is the difference between UTP's $90
basis in its LTP interest and UTP's share of the adjusted basis to LTP
of LTP's property.''
15. On page 3068, third column, paragraph (e)(1)(A) is redesignated
as paragraph (e)(1)(i).
16. On page 3069, first column, paragraph (e)(1)(B) is redesignated
as paragraph (e)(1)(ii).
17. On page 3069, first column, paragraph (e)(2), the language
``(e)(1)(B) ''should read ``(e)(1)(ii)'' wherever it appears.
18. On page 3069, first column, paragraph ``(3) Example.'' Is
corrected to read ``(3) Example.''.
19. On page 3069, first and second column, paragraph (e)(3) should
read ``Example. A, B, and C are equal partners in PRS, a partnership. C
is a corporation. The adjusted basis and fair market value for A's
interests in PRS is $100. PRS owns Capital Asset 1 with an adjusted
basis of $0 and a fair market value of $100, Capital Asset 2 with an
adjusted basis of $150 and a fair market value of $50, and stock in
Corp, a corporation that is related to C under section 267(b), with an
adjusted basis of $250 and fair market value of $150. PRS has a section
754 election in effect. PRS distributes Capital Asset 1 to A in
liquidation of A's interest in PRS. PRS will reduce the basis of its
remaining assets under section 734(b) by $100, to be allocated under
section 755. Pursuant to the general rule of paragraph (c) of this
section, PRS would reduce the basis of Capital Asset 2 by $50 and the
stock of Corp by $50. However, pursuant to paragraph (e)(1)(i) of this
section, the basis of the Corp stock is not adjusted. Thus, the basis
of Capital Asset 2 is reduced by $100 from $150 to $50.''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2014-08360 Filed 4-14-14; 8:45 am]
BILLING CODE 4830-01-P
