Dividend Equivalents From Sources Within the United States, 56415-56416 [2015-21753]

Download as PDF Federal Register / Vol. 80, No. 181 / Friday, September 18, 2015 / Proposed Rules (a) Comments Due Date (j) Other FAA AD Provisions We must receive comments by November 2, 2015. The following provisions also apply to this AD: (1) Alternative Methods of Compliance (AMOCs): The Manager, International Branch, ANM–116, Transport Airplane Directorate, 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: Tom Rodriguez, Aerospace Engineer, International Branch, ANM–116, Transport Airplane Directorate, FAA, 1601 Lind Avenue SW., Renton, WA 98057–3356; telephone 425–227–1137; fax 425 227–1149 Information may be emailed to: 9-ANM-116AMOC-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. (2) Contacting the Manufacturer: For any requirement in this AD to obtain corrective actions from a manufacturer, the action must be accomplished using a method approved by the Manager, International Branch, ANM– 116, Transport Airplane Directorate, FAA; or the European Aviation Safety Agency (EASA); or Fokker B.V. Service’s EASA Design Organization Approval (DOA). If approved by the DOA, the approval must include the DOA-authorized signature. (b) Affected ADs None. (c) Applicability This AD applies to Fokker Services B.V. Model F.27 Mark 200, 300, 400, 500, 600, and 700 airplanes, certificated in any category, all serial numbers. (d) Subject Air Transport Association (ATA) of America Code 28, Fuel. (e) Reason This AD was prompted by a design review conducted by Fokker Services B.V. that indicated no controlled bonding provisions were present on many critical locations outside the fuel tank or connected to the fuel tank wall. We are issuing this AD to prevent an ignition source in the fuel tank vapor space, which could result in a fuel tank explosion and consequent loss of the airplane. (f) Compliance Comply with this AD within the compliance times specified, unless already done. (g) Installation Within 24 months after the effective date of this AD, install additional bonding provisions, in accordance with the Accomplishment Instructions of Fokker F27 Proforma Service Bulletin SBF27–28–072, Revision 1, dated March 6, 2014, including Fokker F27 Service Bulletin Appendix SBF27–28–072/APP01, including List of Drawings/Part Lists, dated July 17, 2014. tkelley on DSK3SPTVN1PROD with PROPOSALS (h) Maintenance or Inspection Program Revision At the later of the times specified in paragraph (h)(1) and (h)(2) of this AD: Revise the airplane maintenance or inspection program, as applicable, by incorporating the fuel airworthiness limitations items and critical design configuration control limitations as identified in Fokker Manual Change Notification—Maintenance Documentation (MCNM) F27–027 dated September 9, 2014. (1) Before further flight after accomplishing the installation required by paragraph (g) of this AD, (2) Within 30 days after the effective date of this AD. (i) No Alternative Actions, Intervals, and/or Critical Design Configuration Control Limitations (CDCCLs) After the maintenance or inspection program, as applicable, has been revised as required by paragraph (h) of this AD, no alternative actions (e.g., inspections), intervals, and/or CDCCLs may be used unless the actions, intervals, and/or CDCCLs are approved as an alternative method of compliance in accordance with the procedures specified in paragraph (j) of this AD. VerDate Sep<11>2014 17:14 Sep 17, 2015 Jkt 235001 DEPARTMENT OF THE TREASURY (k) Related Information (1) Refer to Mandatory Continuing Airworthiness Information (MCAI) EASA Airworthiness Directive 2014–0100, dated April 30, 2014, for related information. This MCAI may be found in the AD docket on the Internet at http://www.regulations.gov by searching for and locating Docket No. FAA– 2015–3633. (2) For service information identified in this AD, contact Fokker Services B.V., Technical Services Dept., P.O. Box 1357, 2130 EL Hoofddorp, the Netherlands; telephone +31 (0)88–6280–350; fax +31 (0)88–6280–111; email technicalservices@ fokker.com; Internet http:// www.myfokkerfleet.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 September 11, 2015. Michael Kaszycki, Acting Manager, Transport Airplane Directorate, Aircraft Certification Service. [FR Doc. 2015–23408 Filed 9–17–15; 8:45 am] BILLING CODE 4910–13–P PO 00000 Frm 00017 Fmt 4702 Sfmt 4702 56415 Internal Revenue Service 26 CFR Part 1 [REG–127895–14] RIN 1545–BM33 Dividend Equivalents From Sources Within the United States Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing. AGENCY: SUMMARY: Written or electronic comments must be received by December 17, 2015. Outlines of topics to be discussed at the public hearing scheduled for January 15, 2016, at 10 a.m. must be received by December 17, 2015. ADDRESSES: Send submissions to CC:PA:LPD:PR (REG–127895–14), 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 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–127895–14), Courier’s desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, DC 20044, or sent electronically, via the Federal eRulemaking Portal at www.regulations.gov (IRS REG–127895– 14). 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 regulations, D. Peter Merkel or Karen Walny at (202) 317– 6938; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing Oluwfunmilayo Taylor at (202) 317–6901 (not toll-free numbers). DATES: SUPPLEMENTARY INFORMATION: Background and Explanation of Provisions Final and temporary regulations in the Rules and Regulations section of this issue of the Federal Register contain amendments to the Income Tax Regulations (26 CFR part 1) which provide rules for determining when a payment made pursuant to certain financial products will be treated as a dividend equivalent for purposes of section 871(m). These proposed regulations provide guidance relating to the substantial equivalence test, which E:\FR\FM\18SEP1.SGM 18SEP1 56416 Federal Register / Vol. 80, No. 181 / Friday, September 18, 2015 / Proposed Rules is used to determine whether a complex contract is a section 871(m) transaction. These proposed regulations also provide guidance to qualified derivatives dealers. The text of those temporary regulations also serves as the text of these proposed regulations. The preamble to the final and temporary regulations explains the temporary regulations and these proposed regulations. The regulations affect nonresident alien individuals, foreign corporations, and withholding agents. tkelley on DSK3SPTVN1PROD with PROPOSALS Special Analyses Certain IRS regulations, including this one, are exempt from the requirements of Executive Order 12866, as supplemented and reaffirmed by Executive Order 13563. Therefore, a regulatory impact 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, and because the regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f), these regulations have been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business. Comments and Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS as prescribed in this preamble under the ADDRESSES heading. The Treasury Department and the IRS request comments on all aspects of the proposed rules. All comments will be available at www.regulations.gov or upon request. A public hearing has been scheduled for January 15, 2016, beginning at 10 a.m. in the Auditorium of the Internal Revenue Building, 1111 Constitution Avenue NW., Washington, DC. Due to building security procedures, visitors must enter 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 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 an outline of the topics to VerDate Sep<11>2014 17:14 Sep 17, 2015 Jkt 235001 be discussed and the time to be devoted to each topic by December 17, 2015. Submit a signed paper or electronic copy of the outline as prescribed in this preamble under the ADDRESSES heading. 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 D. Peter Merkel and Karen Walny of the Office of Chief Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. § 1.1441–1 Requirement for the deduction and withholding of tax on payments to foreign persons. * * * * * (e) * * * (3) * * * (ii) * * * (E) [The text of the proposed amendments to § 1.1441–1(e)(3)(ii)(E) is the same as the text of § 1.1441– 1T(e)(3)(ii)(E) published elsewhere in this issue of the Federal Register.] * * * * * (5) [The text of the proposed amendments to § 1.1441–1(e)(5) is the same as the text of § 1.1441–1T(e)(5) published elsewhere in this issue of the Federal Register.] (6) [The text of the proposed amendments to § 1.1441–1(e)(6) is the same as the text of § 1.1441–1T(e)(6) published elsewhere in this issue of the Federal Register.] John Dalrymple, Deputy Commissioner for Services and Enforcement. Proposed Amendments to the Regulations [FR Doc. 2015–21753 Filed 9–17–15; 8:45 am] Accordingly, 26 CFR part 1 is proposed to be amended as follows: BILLING CODE 4830–01–P PART 1—INCOME TAXES DEPARTMENT OF LABOR Paragraph 1. The authority citation for part 1 continues to read in part as follows: Mine Safety and Health Administration ■ 30 CFR Parts 7 and 75 Authority: 26 U.S.C. 7805 * * * § 1.871–15 also issued under 26 U.S.C. 871(m). * * * [Docket No. MSHA–2013–0033] Par. 2. Section 1.871–15 is amended by revising paragraph (c)(2)(vi) and paragraph (h) to read as follows: Refuge Alternatives for Underground Coal Mines RIN 1219–AB79 ■ § 1.871–15 Treatment of dividend equivalents. * * * * * (c) * * * (2) * * * (iv) [The text of the proposed amendments to § 1.871–15(c)(2)(iv) is the same as the text of § 1.871– 15T(c)(2)(iv) published elsewhere in this issue of the Federal Register.] * * * * * (h) [The text of the proposed amendments to § 1.871–15(h) is the same as the text of § 1.871–15T(h) published elsewhere in this issue of the Federal Register.] * * * * * (q) [The text of the proposed amendments to § 1.871–15(q) is the same as the text of § 1.871–15T(q) published elsewhere in this issue of the Federal Register.] ■ Par. 3. Section 1.1441–1 is amended by revising paragraph (e)(3)(vii) and paragraph (e)(6) to read as follows: PO 00000 Frm 00018 Fmt 4702 Sfmt 4702 Mine Safety and Health Administration, Labor. ACTION: Notice of public meeting; reopening of record. AGENCY: The Mine Safety and Health Administration (MSHA) will hold a public meeting to gather information on issues and options relevant to miners’ escape and refuge. This meeting will supplement the information already received in response to the Agency’s Request for Information on Refuge Alternatives for Underground Coal Mines. This meeting provides coal mine operators, coal miners, manufacturers, academia and other interested stakeholders an opportunity to provide information concerning two critical issues: Impediments to the use of builtin-place refuges and enhanced two-way voice communication when using escape breathing devices. This meeting also invites stakeholders to provide input on the current state of refuges in use and recent research and new SUMMARY: E:\FR\FM\18SEP1.SGM 18SEP1

Agencies

[Federal Register Volume 80, Number 181 (Friday, September 18, 2015)]
[Proposed Rules]
[Pages 56415-56416]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-21753]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-127895-14]
RIN 1545-BM33


Dividend Equivalents From Sources Within the United States

AGENCY: Internal Revenue Service (IRS), Treasury.

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

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

SUMMARY: 

DATES: Written or electronic comments must be received by December 17, 
2015. Outlines of topics to be discussed at the public hearing 
scheduled for January 15, 2016, at 10 a.m. must be received by December 
17, 2015.

ADDRESSES: Send submissions to CC:PA:LPD:PR (REG-127895-14), 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 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
127895-14), Courier's desk, Internal Revenue Service, 1111 Constitution 
Avenue NW., Washington, DC 20044, or sent electronically, via the 
Federal eRulemaking Portal at www.regulations.gov (IRS REG-127895-14). 
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 regulations, D. Peter 
Merkel or Karen Walny at (202) 317-6938; concerning submissions of 
comments, the hearing, and/or to be placed on the building access list 
to attend the hearing Oluwfunmilayo Taylor at (202) 317-6901 (not toll-
free numbers).

SUPPLEMENTARY INFORMATION: 

Background and Explanation of Provisions

    Final and temporary regulations in the Rules and Regulations 
section of this issue of the Federal Register contain amendments to the 
Income Tax Regulations (26 CFR part 1) which provide rules for 
determining when a payment made pursuant to certain financial products 
will be treated as a dividend equivalent for purposes of section 
871(m). These proposed regulations provide guidance relating to the 
substantial equivalence test, which

[[Page 56416]]

is used to determine whether a complex contract is a section 871(m) 
transaction. These proposed regulations also provide guidance to 
qualified derivatives dealers. The text of those temporary regulations 
also serves as the text of these proposed regulations. The preamble to 
the final and temporary regulations explains the temporary regulations 
and these proposed regulations. The regulations affect nonresident 
alien individuals, foreign corporations, and withholding agents.

Special Analyses

    Certain IRS regulations, including this one, are exempt from the 
requirements of Executive Order 12866, as supplemented and reaffirmed 
by Executive Order 13563. Therefore, a regulatory impact 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, and because the regulations do not impose a 
collection of information on small entities, the Regulatory Flexibility 
Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f), 
these regulations have been submitted to the Chief Counsel for Advocacy 
of the Small Business Administration for comment on its impact on small 
business.

Comments and Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any comments that are submitted timely 
to the IRS as prescribed in this preamble under the ADDRESSES heading. 
The Treasury Department and the IRS request comments on all aspects of 
the proposed rules. All comments will be available at 
www.regulations.gov or upon request.
    A public hearing has been scheduled for January 15, 2016, beginning 
at 10 a.m. in the Auditorium of the Internal Revenue Building, 1111 
Constitution Avenue NW., Washington, DC. Due to building security 
procedures, visitors must enter 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 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 an outline of 
the topics to be discussed and the time to be devoted to each topic by 
December 17, 2015. Submit a signed paper or electronic copy of the 
outline as prescribed in this preamble under the ADDRESSES heading. 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 D. Peter Merkel and 
Karen Walny of the Office of Chief Counsel (International). However, 
other personnel from the Treasury Department and the IRS participated 
in their development.

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 * * *
    Sec.  1.871-15 also issued under 26 U.S.C. 871(m). * * *

0
Par. 2. Section 1.871-15 is amended by revising paragraph (c)(2)(vi) 
and paragraph (h) to read as follows:


Sec.  1.871-15  Treatment of dividend equivalents.

* * * * *
    (c) * * *
    (2) * * *
    (iv) [The text of the proposed amendments to Sec.  1.871-
15(c)(2)(iv) is the same as the text of Sec.  1.871-15T(c)(2)(iv) 
published elsewhere in this issue of the Federal Register.]
* * * * *
    (h) [The text of the proposed amendments to Sec.  1.871-15(h) is 
the same as the text of Sec.  1.871-15T(h) published elsewhere in this 
issue of the Federal Register.]
* * * * *
    (q) [The text of the proposed amendments to Sec.  1.871-15(q) is 
the same as the text of Sec.  1.871-15T(q) published elsewhere in this 
issue of the Federal Register.]
0
Par. 3. Section 1.1441-1 is amended by revising paragraph (e)(3)(vii) 
and paragraph (e)(6) to read as follows:


Sec.  1.1441-1  Requirement for the deduction and withholding of tax on 
payments to foreign persons.

* * * * *
    (e) * * *
    (3) * * *
    (ii) * * *
    (E) [The text of the proposed amendments to Sec.  1.1441-
1(e)(3)(ii)(E) is the same as the text of Sec.  1.1441-1T(e)(3)(ii)(E) 
published elsewhere in this issue of the Federal Register.]
* * * * *
    (5) [The text of the proposed amendments to Sec.  1.1441-1(e)(5) is 
the same as the text of Sec.  1.1441-1T(e)(5) published elsewhere in 
this issue of the Federal Register.]
    (6) [The text of the proposed amendments to Sec.  1.1441-1(e)(6) is 
the same as the text of Sec.  1.1441-1T(e)(6) published elsewhere in 
this issue of the Federal Register.]

John Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2015-21753 Filed 9-17-15; 8:45 am]
BILLING CODE 4830-01-P