Amendments for Small and Additional Issues Exemptions Under the Securities Act (Regulation A), 31836-31837 [2015-13627]
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31836
Federal Register / Vol. 80, No. 107 / Thursday, June 4, 2015 / Rules and Regulations
rule. You may send comments regarding
the collection of information associated
with this rule, including suggestions for
reducing the burden, to Jasmeet K.
Seehra, Office of Management and
Budget (OMB), by email to Jasmeet_K._
Seehra@omb.eop.gov, or by fax to (202)
395–7285.
3. This rule does not contain policies
with Federalism implications as that
term is defined in Executive Order
13132.
4. The provisions of the
Administrative Procedure Act (5 U.S.C.
553) requiring notice of proposed
rulemaking, the opportunity for public
comment and a delay in effective date
are inapplicable because this regulation
involves a military or foreign affairs
function of the United States. (See 5
U.S.C. 553(a)(1)). BIS implements this
rule to protect U.S. national security or
foreign policy interests by preventing
items from being exported, reexported,
or transferred (in country) to the person
being added to the Entity List. If this
rule were delayed to allow for notice
and comment and a delay in effective
date, then the entity being added to the
Entity List by this action would
continue to be able to receive items
without a license and to conduct
activities contrary to the national
Country
security or foreign policy interests of the
United States. In addition, publishing a
proposed rule would give this party
notice of the U.S. Government’s
intention to place them on the Entity
List and would create an incentive for
this person to either accelerate receiving
items subject to the EAR to conduct
activities that are contrary to the
national security or foreign policy
interests of the United States, and/or to
take steps to set up additional aliases,
change addresses, and other measures to
try to limit the impact of the listing on
the Entity List once a final rule was
published. Further, no other law
requires that a notice of proposed
rulemaking and an opportunity for
public comment be given for this rule.
Because a notice of proposed
rulemaking and an opportunity for
public comment are not required to be
given for this rule by 5 U.S.C. 553, or
by any other law, the analytical
requirements of the Regulatory
Flexibility Act, 5 U.S.C. 601 et seq., are
not applicable. Accordingly, no
regulatory flexibility analysis is required
and none has been prepared.
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ECUADOR .......
Supplement No. 4 to Part 744—Entity
List
License
requirement
[FR Doc. 2015–13632 Filed 6–3–15; 8:45 am]
BILLING CODE 3510–33–P
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SECURITIES AND EXCHANGE
COMMISSION
17 CFR Parts 200, 230, 232, 239, 240,
249, and 260
[Release Nos. 33–9741A; 34–74578A; 39–
2501A; File No. S7–11–13]
srobinson on DSK5SPTVN1PROD with RULES
Securities and Exchange
Commission.
ACTION: Final rule; correction.
AGENCY:
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Amendments for Small and Additional
Issues Exemptions Under the
Securities Act (Regulation A)
19:38 Jun 03, 2015
Federal Register citation
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For items classified under Case-by-case review .......
Export Control Classification Numbers
(ECCNs) 5D002 or
5A002. (See § 744.11 of
the EAR).
RIN 3235–AL39
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License
review policy
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Dated: May 29, 2015.
Matthew S. Borman,
Deputy Assistant Secretary for Export
Administration.
Authority: 50 U.S.C. app. 2401 et seq.; 50
U.S.C. 1701 et seq.; 22 U.S.C. 3201 et seq.;
42 U.S.C. 2139a; 22 U.S.C. 7201 et seq.; 22
U.S.C. 7210; E.O. 12058, 43 FR 20947, 3 CFR,
1978 Comp., p. 179; E.O. 12851, 58 FR 33181,
3 CFR, 1993 Comp., p. 608; E.O. 12938, 59
FR 59099, 3 CFR, 1994 Comp., p. 950; E.O.
12947, 60 FR 5079, 3 CFR, 1995 Comp., p.
356; E.O. 13026, 61 FR 58767, 3 CFR, 1996
Comp., p. 228; E.O. 13099, 63 FR 45167, 3
CFR, 1998 Comp., p. 208; E.O. 13222, 66 FR
44025, 3 CFR, 2001 Comp., p. 783; E.O.
13224, 66 FR 49079, 3 CFR, 2001 Comp., p.
786; Notice of August 7, 2014, 79 FR 46959
(August 11, 2014); Notice of September 17,
2014, 79 FR 56475 (September 19, 2014);
Notice of November 7, 2014, 79 FR 67035
(November 12, 2014); Notice of January 21,
2015, 80 FR 3461 (January 22, 2015).
Exports, Reporting and recordkeeping
requirements, Terrorism.
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1. The authority citation for 15 CFR
part 744 continues to read as follows:
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List of Subjects in 15 CFR Part 744
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Corporacion
Nacional
de
Telecommunicaciones
(CNT),
Avenida Gaspar de Villaroel Quito,
Ecuador; and Avda. Veintimilla, Suite
1149 y Amazonas, Edificio Estudio Z,
Quito, Ecuador.
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PART 744—[AMENDED]
2. Supplement No. 4 to part 744 is
amended by adding in alphabetical
order the destination of Ecuador under
the Country Column, and one
Ecuadorian entity to read as follows:
Entity
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Accordingly, part 744 of the Export
Administration Regulations (15 CFR
parts 730–774) is amended as follows:
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80 FR [INSERT FR PAGE
NUMBER] 6/4/15.
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This document corrects an
instruction for the authority to part 200
in a final rule published in the Federal
Register of April 20, 2015 regarding the
Amendments for Small and Additional
Issues Exemptions under the Securities
Act (Regulation A).
DATES: This correction is effective June
19, 2015.
FOR FURTHER INFORMATION CONTACT:
Naomi P. Lewis, Office of the Secretary
at (202) 551–5400.
SUPPLEMENTARY INFORMATION: In FR
Document No. 2015–07305, published
on April 20, 2015, on page 21894, third
column, 5th line, instruction number 1
should read as follows:
SUMMARY:
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Federal Register / Vol. 80, No. 107 / Thursday, June 4, 2015 / Rules and Regulations
1. The authority citation for part 200,
subpart A is revised to read, in part, as
follows:
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Dated: June 1, 2015.
Brent J. Fields,
Secretary.
[FR Doc. 2015–13627 Filed 6–3–15; 8:45 am]
BILLING CODE 8011–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9720]
RIN 1545–BK85
Substantial Business Activities
Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulations.
AGENCY:
This document contains final
regulations regarding when an
expanded affiliated group will be
considered to have substantial business
activities in a foreign country. These
regulations affect certain domestic
corporations and partnerships (and
certain parties related to them), and
foreign corporations that acquire
substantially all of the properties of
such domestic corporations or
partnerships.
SUMMARY:
DATES:
Effective date: These regulations are
effective on June 4, 2015.
Applicability date: For date of
applicability, see § 1.7874–3(f).
FOR FURTHER INFORMATION CONTACT:
David A. Levine, (202) 317–6937 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
srobinson on DSK5SPTVN1PROD with RULES
Background
On June 6, 2006, temporary
regulations under section 7874 (TD
9265) were published in the Federal
Register (71 FR 32437) concerning the
treatment of a foreign corporation as a
surrogate foreign corporation (2006
temporary regulations). A notice of
proposed rulemaking (REG–112994–06)
cross-referencing the 2006 temporary
regulations was published in the same
issue of the Federal Register (71 FR
32495). On July 28, 2006, Notice 2006–
70 (2006–2 CB 252) was published,
announcing a modification to the
effective date contained in the 2006
temporary regulations. See
§ 601.601(d)(2)(ii)(b). On June 12, 2009,
the 2006 temporary regulations and the
related notice of proposed rulemaking
were withdrawn and replaced with new
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temporary regulations (2009 temporary
regulations), which generally apply to
acquisitions completed on or after June
9, 2009. TD 9453 (74 FR 27920). A
notice of proposed rulemaking (REG–
112994–06) cross-referencing the 2009
temporary regulations was published in
the same issue of the Federal Register
(74 FR 27947). On June 12, 2012, the
2009 temporary regulations and the
related notice of proposed rulemaking
were withdrawn and replaced with new
temporary regulations (2012 temporary
regulations), which generally apply to
acquisitions completed on or after June
7, 2012. TD 9592 (77 FR 34785). A
notice of proposed rulemaking (REG–
107889–12) cross-referencing the 2012
temporary regulations was published in
the same issue of the Federal Register
(77 FR 34887). No public hearing was
requested or held; however, comments
were received. All comments are
available at www.regulations.gov or
upon request. After consideration of the
comments, the 2012 temporary
regulations are adopted as final
regulations with the modifications
described in this preamble. The 2012
temporary regulations are removed.
Explanation of Revisions and Summary
of Comments
A. General Approach
A foreign corporation generally is
treated as a surrogate foreign
corporation under section 7874(a)(2)(B)
if pursuant to a plan (or a series of
related transactions): (i) The foreign
corporation completes after March 4,
2003, the direct or indirect acquisition
of substantially all of the properties held
directly or indirectly by a domestic
corporation (acquisition); (ii) after the
acquisition, at least 60 percent of the
stock (by vote or value) of the foreign
corporation is held by former
shareholders of the domestic
corporation by reason of holding stock
in the domestic corporation; and (iii)
after the acquisition, the expanded
affiliated group that includes the foreign
corporation (EAG) does not have
substantial business activities in the
foreign country in which, or under the
law of which, the foreign corporation is
created or organized (relevant foreign
country), when compared to the total
business activities of the EAG. Similar
provisions apply if a foreign corporation
acquires substantially all of the
properties constituting a trade or
business of a domestic partnership.
The 2009 temporary regulations
provided that whether an EAG will be
considered to have substantial business
activities in the relevant foreign country
is based on all the facts and
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31837
circumstances and, unlike the 2006
temporary regulations, did not provide
a safe harbor. The 2012 temporary
regulations replaced this facts-andcircumstances test with a bright-line
rule describing the threshold of
activities required for an EAG to be
considered to have substantial business
activities in the relevant foreign
country. Under this bright-line rule, an
EAG will be considered to have
substantial business activities in the
relevant foreign country only if at least
25 percent of the group employees,
group assets, and group income are
located or derived in the relevant
foreign country.
Some comments criticized this
approach and asserted that there is
insufficient support for this bright-line
rule in the legislative history. In
addition, some comments recommended
reverting to a general facts and
circumstances test, along with a safe
harbor, given the difficulty of
formulating a bright-line rule that
produces appropriate results in all
circumstances. As an alternative,
comments suggested that the failure to
satisfy the bright-line rule could
establish a rebuttable presumption that
an EAG does not have substantial
business activities in the relevant
foreign country.
After consideration of the comments,
the Department of the Treasury
(Treasury Department) and the IRS have
concluded that the bright-line rule in
the 2012 temporary regulations is
consistent with section 7874 and its
underlying policies. In addition, the
bright-line rule has proven more
administrable than a facts-andcircumstances test and has the benefit of
providing certainty in applying section
7874 to particular transactions. As a
result, these final regulations retain the
bright-line rule subject to certain
modifications, which are described in
this preamble.
B. Threshold of Business Activities
As described in section A of this
preamble, the 2012 temporary
regulations provide that an EAG will be
considered to have substantial business
activities in the relevant foreign country
only if at least 25 percent of its group
employees, group assets, and group
income are located or derived in the
relevant foreign country. Comments
addressed both the magnitude of the 25percent threshold and the requirement
that each of the group employees, group
assets, and group income tests must be
satisfied. Although one comment stated
that a 25-percent threshold is a
reasonable measure of substantiality,
other comments stated that it is overly
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Agencies
[Federal Register Volume 80, Number 107 (Thursday, June 4, 2015)]
[Rules and Regulations]
[Pages 31836-31837]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-13627]
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SECURITIES AND EXCHANGE COMMISSION
17 CFR Parts 200, 230, 232, 239, 240, 249, and 260
[Release Nos. 33-9741A; 34-74578A; 39-2501A; File No. S7-11-13]
RIN 3235-AL39
Amendments for Small and Additional Issues Exemptions Under the
Securities Act (Regulation A)
AGENCY: Securities and Exchange Commission.
ACTION: Final rule; correction.
-----------------------------------------------------------------------
SUMMARY: This document corrects an instruction for the authority to
part 200 in a final rule published in the Federal Register of April 20,
2015 regarding the Amendments for Small and Additional Issues
Exemptions under the Securities Act (Regulation A).
DATES: This correction is effective June 19, 2015.
FOR FURTHER INFORMATION CONTACT: Naomi P. Lewis, Office of the
Secretary at (202) 551-5400.
SUPPLEMENTARY INFORMATION: In FR Document No. 2015-07305, published on
April 20, 2015, on page 21894, third column, 5th line, instruction
number 1 should read as follows:
[[Page 31837]]
0
1. The authority citation for part 200, subpart A is revised to read,
in part, as follows:
Dated: June 1, 2015.
Brent J. Fields,
Secretary.
[FR Doc. 2015-13627 Filed 6-3-15; 8:45 am]
BILLING CODE 8011-01-P