Amendment to the International Traffic in Arms Regulations: Policy on Exports to Vietnam, 66615-66616 [2014-26632]
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Federal Register / Vol. 79, No. 217 / Monday, November 10, 2014 / Rules and Regulations
66615
Rose E. Gottemoeller,
Under Secretary, Arms Control and
International Security, Department of State.
impracticable, unnecessary, or contrary
to the public interest; for this reason, the
rule is effective upon publication.
18, 2011, and affirms that this regulation
is consistent with the guidance therein.
[FR Doc. 2014–26631 Filed 11–7–14; 8:45 am]
Regulatory Flexibility Act
22 CFR Part 126
Since the Department is of the
opinion that this rule is exempt from the
provisions of 5 U.S.C. 553, there is no
requirement for an analysis under the
Regulatory Flexibility Act.
The Department of State has reviewed
this rulemaking in light of sections 3(a)
and 3(b)(2) of Executive Order 12988 to
eliminate ambiguity, minimize
litigation, establish clear legal
standards, and reduce burden.
[Public Notice 8943]
Unfunded Mandates Reform Act of 1995
Executive Order 13175
RIN 1400–AD73
This rulemaking does not involve a
mandate that will result in the
expenditure by State, local, and tribal
governments, in the aggregate, or by the
private sector, of $100 million or more
in any year and it will not significantly
or uniquely affect small governments.
Therefore, no actions were deemed
necessary under the provisions of the
Unfunded Mandates Reform Act of
1995.
The Department of State has
determined that this rulemaking will
not have tribal implications, will not
impose substantial direct compliance
costs on Indian tribal governments, and
will not pre-empt tribal law.
Accordingly, the provisions of
Executive Order 13175 do not apply to
this rulemaking.
Small Business Regulatory Enforcement
Fairness Act of 1996
This rule does not impose any new
reporting or record-keeping
requirements subject to the Paperwork
Reduction Act, 44 U.S.C. Chapter 35.
BILLING CODE 4710–25–P
DEPARTMENT OF STATE
Amendment to the International Traffic
in Arms Regulations: Policy on
Exports to Vietnam
Department of State.
Final rule.
AGENCY:
ACTION:
The Department of State is
revising the International Traffic in
Arms Regulations (ITAR) to reflect a
change in its policy on exports to
Vietnam.
SUMMARY:
This rule is effective on
November 10, 2014.
DATES:
Mr.
C. Edward Peartree, Director, Office of
Defense Trade Controls Policy,
Department of State, telephone (202)
663–2792; email
DDTCPublicComments@state.gov.
ATTN: Regulatory Change, Exports to
Vietnam.
FOR FURTHER INFORMATION CONTACT:
The
Department has determined that is in
the best interests of U.S. foreign policy,
national security, and human rights
concerns that exports of lethal defense
articles and defense services to Vietnam
may be authorized on a case-by-case
basis when in support of maritime
security and domain awareness.
SUPPLEMENTARY INFORMATION:
Regulatory Analysis and Notices
rmajette on DSK2TPTVN1PROD with RULES
Administrative Procedure Act
The Department of State is of the
opinion that controlling the import and
export of defense articles and services is
a foreign affairs function of the United
States Government and that rules
implementing this function are exempt
from sections 553 (rulemaking) and 554
(adjudications) of the Administrative
Procedure Act (APA), pursuant to 5
U.S.C. 553(a)(1). Since the Department
is of the opinion that this rule is exempt
from 5 U.S.C 553, it is the view of the
Department that the provisions of
Section 553(d) do not apply to this
rulemaking. Therefore, this rule is
effective upon publication. The
Department also finds that, given the
national security issues surrounding
U.S. policy toward Vietnam, notice and
public procedure on this rule would be
VerDate Sep<11>2014
14:43 Nov 07, 2014
Jkt 235001
This rulemaking has been found not
to be a major rule within the meaning
of the Small Business Regulatory
Enforcement Fairness Act of 1996.
Executive Orders 12372 and 13132
This rulemaking will not have
substantial direct effects on the States,
on the relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
levels of government. Therefore, in
accordance with Executive Order 13132,
it is determined that this rulemaking
does not have sufficient federalism
implications to require consultations or
warrant the preparation of a federalism
summary impact statement. The
regulations implementing Executive
Order 12372 regarding
intergovernmental consultation on
Federal programs and activities do not
apply to this rulemaking.
Executive Order 12866
Executive Order 13563
The Department of State has
considered this rule in light of
Executive Order 13563, dated January
Frm 00025
Fmt 4700
Sfmt 4700
Paperwork Reduction Act
List of Subjects in 22 CFR Part 126
Arms and munitions, Exports.
For the reasons set forth above, 22
CFR part 126 is amended as follows:
PART 126—GENERAL POLICIES AND
PROVISIONS
1. The authority citation for part 126
continues to read as follows:
■
Authority: Secs. 2, 38, 40, 42, and 71, Pub.
L. 90–629, 90 Stat. 744 (22 U.S.C. 2752, 2778,
2780, 2791, and 2797); 22 U.S.C. 2651a; 22
U.S.C. 287c; E.O. 12918, 59 FR 28205; 3 CFR,
1994 Comp., p. 899; Sec. 1225, Pub. L. 108–
375; Sec. 7089, Pub. L. 111–117; Pub. L. 111–
266; Sections 7045 and 7046, Pub. L. 112–74;
E.O. 13637, 78 FR 16129.
2. Section 126.1(l) is revised to read as
follows:
■
§ 126.1 Prohibited exports, imports, and
sales to or from certain countries.
*
The Department is of the opinion that
controlling the import and export of
defense articles and services is a foreign
affairs function of the United States
Government and that rules governing
the conduct of this function are exempt
from the requirements of Executive
Order 12866. However, the Department
has reviewed the rule to ensure its
consistency with the regulatory
philosophy and principles set forth in
the Executive Order.
PO 00000
Executive Order 12988
*
*
*
*
(l) Vietnam. It is the policy of the
United States to deny licenses or other
approvals for exports or imports of
defense articles and defense services
destined for or originating in Vietnam,
except that a license or other approval
may be issued, on a case-by-case basis,
for:
(1) Lethal defense articles and defense
services to enhance maritime security
capabilities and domain awareness;
(2) Non-lethal defense articles and
defense services; or,
(3) Non-lethal, safety-of-use defense
articles (e.g., cartridge actuated devices,
propellant actuated devices and
technical manuals for military aircraft
E:\FR\FM\10NOR1.SGM
10NOR1
66616
Federal Register / Vol. 79, No. 217 / Monday, November 10, 2014 / Rules and Regulations
for purposes of enhancing the safety of
the aircraft crew) for lethal end-items.
Note to paragraph (l). For non-lethal
defense end-items, no distinction will be
made between Vietnam’s existing and new
inventory.
*
*
*
*
*
Rose E. Gottemoeller,
Under Secretary, Arms Control and
International Security, Department of State.
[FR Doc. 2014–26632 Filed 11–7–14; 8:45 am]
BILLING CODE 4710–05–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9700]
RINs 1545–BK73; 1545–BL80
Allocation of Earnings and Profits in
Tax-Free Transfers From One
Corporation to Another; Acquiring
Corporation for Purposes of Section
381
Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulations.
AGENCY:
This document contains final
regulations under section 312 of the
Internal Revenue Code (Code) that
clarify the regulations under section 312
regarding the allocation of earnings and
profits in tax-free transfers from one
corporation to another. These
regulations affect corporations involved
in these transfers and their
shareholders. This document also
contains final regulations under section
381 of the Code that modify the
definition of an acquiring corporation
for purposes of section 381 with regard
to certain acquisitions of assets. These
regulations affect corporations that
acquire the assets of other corporations
in corporate reorganizations.
DATES: Effective Date: These regulations
are effective on November 10, 2014.
Applicability Date: These regulations
apply to transactions occurring on or
after November 10, 2014.
FOR FURTHER INFORMATION CONTACT:
Stephanie D. Floyd at (202) 317–6848 or
Isaac W. Zimbalist at (202) 317–6847
(not toll-free numbers).
SUPPLEMENTARY INFORMATON:
rmajette on DSK2TPTVN1PROD with RULES
SUMMARY:
Background
This document contains amendments
to 26 CFR part 1 under section 312 and
section 381 of the Code. On April 16,
2012, the IRS and the Treasury
VerDate Sep<11>2014
14:43 Nov 07, 2014
Jkt 235001
Department published a notice of
proposed rulemaking (REG–141268–11)
in the Federal Register (77 FR 22515)
containing proposed regulations under
section 312 (proposed section 312
regulations) to clarify § 1.312–11
regarding the allocation of earnings and
profits in nonrecognition transfers of
property from one corporation to
another. The proposed section 312
regulations provided that, in a transfer
described in section 381(a) (section 381
transaction), the acquiring corporation,
as defined in § 1.381(a)–1(b)(2), would
succeed to the earnings and profits of
the distributor or transferor corporation.
For example, in a reorganization under
section 368(a)(1) by reason of section
368(a)(2)(C), if the transferee
corporation that directly acquires a
transferor corporation’s assets
transferred some, but not all, of the
acquired assets to a controlled
subsidiary, the transferee corporation
(the acquiring corporation under
§ 1.381(a)–1(b)(2)) would succeed to the
transferor corporation’s earnings and
profits. However, if the transferee
corporation instead transferred all of the
acquired assets to a controlled
subsidiary, then the controlled
subsidiary (the acquiring corporation
under § 1.381(a)–1(b)(2)) would succeed
to the transferor corporation’s earnings
and profits.
Comments responding to the
proposed section 312 regulations were
received, but no public hearing was
requested or held. In response to the
comments received on the proposed
section 312 regulations, on May 7, 2014,
the IRS and the Treasury Department
published a notice of proposed
rulemaking (REG–131239–13) in the
Federal Register (79 FR 26190)
containing proposed regulations under
section 381 (proposed section 381
regulations) to modify the definition of
an acquiring corporation for purposes of
section 381 with regard to certain
acquisitions of assets. As discussed in
the preamble to the proposed section
381 regulations, commenters generally
welcomed the apparent certainty
provided by the proposed section 312
regulations regarding the location of the
transferor corporation’s earnings and
profits. However, commenters suggested
that this certainty was illusory because
the existing definition of ‘‘acquiring
corporation’’ under § 1.381(a)–1(b)(2)
focused on whether the direct transferee
corporation in a reorganization further
transferred all of the assets it received
in the section 381 transaction. Thus,
commenters suggested that the existing
regulations under section 381 should be
revised to limit the degree of electivity
PO 00000
Frm 00026
Fmt 4700
Sfmt 4700
regarding the identity of the acquiring
corporation, as well as the uncertainty
regarding whether all of the assets
transferred in the section 381
transaction were further transferred to a
single controlled corporation.
The proposed section 381 regulations
provided greater certainty regarding the
identity of the acquiring corporation by
providing that, in a transaction
described in section 381(a)(2), the term
acquiring corporation means the
corporation that directly acquired the
assets transferred by the transferor
corporation, even if the direct transferee
corporation ultimately retained none of
the assets so transferred. As discussed
in the preamble to the proposed section
381 regulations, the IRS and the
Treasury Department believe that this
rule is appropriate with respect to
determining the location of the earnings
and profits (as well as other tax
attributes) of a transferor corporation
because it generally maintains such
earnings and profits at the corporation
closest to the transferor corporation’s
former shareholders in a manner that
minimizes electivity and administrative
burden. No comments were received in
response to the proposed section 381
regulations, and no public hearing was
requested or held.
Explanation of Provisions
The proposed section 381 regulations
are adopted without substantive change
by this Treasury decision. Because the
proposed section 312 regulations merely
cross-reference the section 381
regulations, this Treasury decision also
adopts the proposed section 312
regulations without substantive change.
However, these final regulations make
a clarifying, non-substantive change to
the proposed section 312 regulations.
The proposed section 312 regulations
provided that ‘‘[e]xcept as provided in
§ 1.312–10, in all other cases in which
property is transferred from one
corporation to another and no gain or
loss is recognized (or is recognized only
to the extent of the property received
other than that permitted to be received
without the recognition of gain), no
allocation of the earnings and profits of
the transferor is made to the transferee.’’
These final regulations remove the
language ‘‘and no gain or loss is
recognized (or is recognized only to the
extent of the property received other
than that permitted to be received
without the recognition of gain).’’ The
IRS and the Treasury Department
believe this language may
inappropriately imply that allocation of
earnings and profits may be permitted
in cases in which gain not expressly
described is recognized on the transfer
E:\FR\FM\10NOR1.SGM
10NOR1
Agencies
[Federal Register Volume 79, Number 217 (Monday, November 10, 2014)]
[Rules and Regulations]
[Pages 66615-66616]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-26632]
-----------------------------------------------------------------------
DEPARTMENT OF STATE
22 CFR Part 126
[Public Notice 8943]
RIN 1400-AD73
Amendment to the International Traffic in Arms Regulations:
Policy on Exports to Vietnam
AGENCY: Department of State.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: The Department of State is revising the International Traffic
in Arms Regulations (ITAR) to reflect a change in its policy on exports
to Vietnam.
DATES: This rule is effective on November 10, 2014.
FOR FURTHER INFORMATION CONTACT: Mr. C. Edward Peartree, Director,
Office of Defense Trade Controls Policy, Department of State, telephone
(202) 663-2792; email DDTCPublicComments@state.gov. ATTN: Regulatory
Change, Exports to Vietnam.
SUPPLEMENTARY INFORMATION: The Department has determined that is in the
best interests of U.S. foreign policy, national security, and human
rights concerns that exports of lethal defense articles and defense
services to Vietnam may be authorized on a case-by-case basis when in
support of maritime security and domain awareness.
Regulatory Analysis and Notices
Administrative Procedure Act
The Department of State is of the opinion that controlling the
import and export of defense articles and services is a foreign affairs
function of the United States Government and that rules implementing
this function are exempt from sections 553 (rulemaking) and 554
(adjudications) of the Administrative Procedure Act (APA), pursuant to
5 U.S.C. 553(a)(1). Since the Department is of the opinion that this
rule is exempt from 5 U.S.C 553, it is the view of the Department that
the provisions of Section 553(d) do not apply to this rulemaking.
Therefore, this rule is effective upon publication. The Department also
finds that, given the national security issues surrounding U.S. policy
toward Vietnam, notice and public procedure on this rule would be
impracticable, unnecessary, or contrary to the public interest; for
this reason, the rule is effective upon publication.
Regulatory Flexibility Act
Since the Department is of the opinion that this rule is exempt
from the provisions of 5 U.S.C. 553, there is no requirement for an
analysis under the Regulatory Flexibility Act.
Unfunded Mandates Reform Act of 1995
This rulemaking does not involve a mandate that will result in the
expenditure by State, local, and tribal governments, in the aggregate,
or by the private sector, of $100 million or more in any year and it
will not significantly or uniquely affect small governments. Therefore,
no actions were deemed necessary under the provisions of the Unfunded
Mandates Reform Act of 1995.
Small Business Regulatory Enforcement Fairness Act of 1996
This rulemaking has been found not to be a major rule within the
meaning of the Small Business Regulatory Enforcement Fairness Act of
1996.
Executive Orders 12372 and 13132
This rulemaking will not have substantial direct effects on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various levels of government. Therefore, in accordance with Executive
Order 13132, it is determined that this rulemaking does not have
sufficient federalism implications to require consultations or warrant
the preparation of a federalism summary impact statement. The
regulations implementing Executive Order 12372 regarding
intergovernmental consultation on Federal programs and activities do
not apply to this rulemaking.
Executive Order 12866
The Department is of the opinion that controlling the import and
export of defense articles and services is a foreign affairs function
of the United States Government and that rules governing the conduct of
this function are exempt from the requirements of Executive Order
12866. However, the Department has reviewed the rule to ensure its
consistency with the regulatory philosophy and principles set forth in
the Executive Order.
Executive Order 13563
The Department of State has considered this rule in light of
Executive Order 13563, dated January 18, 2011, and affirms that this
regulation is consistent with the guidance therein.
Executive Order 12988
The Department of State has reviewed this rulemaking in light of
sections 3(a) and 3(b)(2) of Executive Order 12988 to eliminate
ambiguity, minimize litigation, establish clear legal standards, and
reduce burden.
Executive Order 13175
The Department of State has determined that this rulemaking will
not have tribal implications, will not impose substantial direct
compliance costs on Indian tribal governments, and will not pre-empt
tribal law. Accordingly, the provisions of Executive Order 13175 do not
apply to this rulemaking.
Paperwork Reduction Act
This rule does not impose any new reporting or record-keeping
requirements subject to the Paperwork Reduction Act, 44 U.S.C. Chapter
35.
List of Subjects in 22 CFR Part 126
Arms and munitions, Exports.
For the reasons set forth above, 22 CFR part 126 is amended as
follows:
PART 126--GENERAL POLICIES AND PROVISIONS
0
1. The authority citation for part 126 continues to read as follows:
Authority: Secs. 2, 38, 40, 42, and 71, Pub. L. 90-629, 90
Stat. 744 (22 U.S.C. 2752, 2778, 2780, 2791, and 2797); 22 U.S.C.
2651a; 22 U.S.C. 287c; E.O. 12918, 59 FR 28205; 3 CFR, 1994 Comp.,
p. 899; Sec. 1225, Pub. L. 108-375; Sec. 7089, Pub. L. 111-117; Pub.
L. 111-266; Sections 7045 and 7046, Pub. L. 112-74; E.O. 13637, 78
FR 16129.
0
2. Section 126.1(l) is revised to read as follows:
Sec. 126.1 Prohibited exports, imports, and sales to or from certain
countries.
* * * * *
(l) Vietnam. It is the policy of the United States to deny licenses
or other approvals for exports or imports of defense articles and
defense services destined for or originating in Vietnam, except that a
license or other approval may be issued, on a case-by-case basis, for:
(1) Lethal defense articles and defense services to enhance
maritime security capabilities and domain awareness;
(2) Non-lethal defense articles and defense services; or,
(3) Non-lethal, safety-of-use defense articles (e.g., cartridge
actuated devices, propellant actuated devices and technical manuals for
military aircraft
[[Page 66616]]
for purposes of enhancing the safety of the aircraft crew) for lethal
end-items.
Note to paragraph (l). For non-lethal defense end-items, no
distinction will be made between Vietnam's existing and new
inventory.
* * * * *
Rose E. Gottemoeller,
Under Secretary, Arms Control and International Security, Department
of State.
[FR Doc. 2014-26632 Filed 11-7-14; 8:45 am]
BILLING CODE 4710-05-P