United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction, 66415-66416 [2015-27603]
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Federal Register / Vol. 80, No. 209 / Thursday, October 29, 2015 / Rules and Regulations
the specifications found in the
Accomplishment Instructions of GippsAero
Mandatory Service Bulletin SB–GA8–2014–
115, Issue 1, dated October 6, 2014, before
further flight, re-install the isolators to the
correct orientation, or if damage is found,
replace with airworthy parts.
(g) Other FAA AD Provisions
The following provisions also apply to this
AD:
(1) Alternative Methods of Compliance
(AMOCs): The Manager, Standards Office,
FAA, has the authority to approve AMOCs
for this AD, if requested using the procedures
found in 14 CFR 39.19. Send information to
ATTN: Doug Rudolph, Aerospace Engineer,
FAA, Small Airplane Directorate, 901 Locust,
Room 301, Kansas City, Missouri 64106;
telephone: (816) 329–4059; fax: (816) 329–
4090; email: doug.rudolph@faa.gov. Before
using any approved AMOC on any airplane
to which the AMOC applies, notify your
appropriate principal inspector (PI) in the
FAA Flight Standards District Office (FSDO),
or lacking a PI, your local FSDO.
(2) Airworthy Product: For any requirement
in this AD to obtain corrective actions from
a manufacturer or other source, use these
actions if they are FAA-approved. Corrective
actions are considered FAA-approved if they
are approved by the State of Design Authority
(or their delegated agent). You are required
to assure the product is airworthy before it
is returned to service.
rmajette on DSK7SPTVN1PROD with RULES
(h) Related Information
Refer to MCAI Civil Aviation Safety
Authority (CASA) AD No. AD/GA8/8, Amdt
1, dated March 26, 2015. The MCAI can be
found in the AD docket on the Internet at:
https://www.regulations.gov/
#!documentDetail;D=FAA-2014-1123-0007.
(i) Material Incorporated by Reference
(1) The Director of the Federal Register
approved the incorporation by reference
(IBR) of the service information listed in this
paragraph under 5 U.S.C. 552(a) and 1 CFR
part 51.
(2) You must use this service information
as applicable to do the actions required by
this AD, unless the AD specifies otherwise.
(3) The following service information was
approved for IBR on April 24, 2015 (80 FR
14810, March 20, 2015).
(i) GippsAero Mandatory Service Bulletin
SB–GA8–2014–115, Issue 1, dated October 6,
2014.
(ii) Reserved.
(4) For GippsAero service information
identified in this AD, contact GA 8 Airvan
(Pty) Ltd, c/o GippsAero Pty Ltd, Attn:
Technical Services, P.O. Box 881, Morwell
Victoria 3840, Australia; telephone: + 61 03
5172 1200; fax: +61 03 5172 1201; email:
techpubs@gippsaero.com; Internet: https://
www.gippsaero.com/customer-support/
technical-publications.aspx.
(5) You may view this service information
at the FAA, Small Airplane Directorate, 901
Locust, Kansas City, Missouri 64106. For
information on the availability of this
material at the FAA, call (816) 329–4148. In
addition, you can access this service
information on the Internet at https://
VerDate Sep<11>2014
13:13 Oct 28, 2015
Jkt 238001
www.regulations.gov by searching for and
locating Docket No. FAA–2014–1123.
(6) You may view this service information
that is incorporated by reference at the
National Archives and Records
Administration (NARA). For information on
theavailability of this material at NARA, call
202–741–6030, or go to: https://
www.archives.gov/federal-register/cfr/ibrlocations.html.
Issued in Kansas City, Missouri, on
October 22, 2015.
Melvin Johnson,
Acting Manager, Small Airplane Directorate,
Aircraft Certification Service.
[FR Doc. 2015–27438 Filed 10–28–15; 8:45 am]
BILLING CODE 4910–13–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
21 CFR Part 73
[Docket No. FDA–2014–C–1552]
Listing of Color Additives Exempt
From Certification; Spirulina Extract;
Confirmation of Effective Date
AGENCY:
Food and Drug Administration,
HHS.
Final rule; confirmation of
effective date.
ACTION:
The Food and Drug
Administration (FDA or we) is
confirming the effective date of
September 22, 2015, for the final rule
that appeared in the Federal Register of
August 21, 2015, and that amended the
color additive regulations to expand the
permitted use of spirulina extract as a
color additive to include use in coating
formulations applied to dietary
supplement and drug tablets and
capsules.
SUMMARY:
Effective date of final rule
published in the Federal Register of
August 21, 2015 (80 FR 50762),
confirmed: September 22, 2015.
FOR FURTHER INFORMATION CONTACT:
Molly A. Harry, Center for Food Safety
and Applied Nutrition (HFS–265), Food
and Drug Administration, 5100 Paint
Branch Pkwy., College Park, MD 20740–
3835, 240–402–1075.
SUPPLEMENTARY INFORMATION: In the
Federal Register of August 21, 2015 (80
FR 50762), we amended the color
additive regulations in § 73.530
Spirulina extract (21 CFR 73.530) to
expand the permitted use of spirulina
extract as a color additive to include use
in coating formulations applied to
dietary supplement tablets and
capsules. We also amended the color
DATES:
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Fmt 4700
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66415
additive regulations to add § 73.1530
Spirulina extract (21 CFR 73.1530) to
provide for the safe use of spirulina
extract as a color additive in coating
formulations applied to drug tablets and
capsules.
We gave interested persons until
September 21, 2015, to file objections or
requests for a hearing. We received no
objections or requests for a hearing on
the final rule. Therefore, we find that
the effective date of the final rule that
published in the Federal Register of
August 21, 2015, should be confirmed.
List of Subjects in 21 CFR Part 73
Color additives, Cosmetics, Drugs,
Foods, Medical devices.
Therefore, under the Federal Food,
Drug, and Cosmetic Act (21 U.S.C. 321,
341, 342, 343, 348, 351, 352, 355, 361,
362, 371, 379e) and under authority
delegated to the Commissioner of Food
and Drugs, and redelegated to the
Director, Center for Food Safety and
Applied Nutrition, we are giving notice
that no objections or requests for a
hearing were filed in response to the
August 21, 2015, final rule.
Accordingly, the amendments issued
thereby became effective September 22,
2015.
Dated: October 21, 2015.
Susan Bernard,
Director, Office of Regulations, Policy and
Social Sciences, Center for Food Safety and
Applied Nutrition.
[FR Doc. 2015–27369 Filed 10–28–15; 8:45 am]
BILLING CODE 4164–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9733]
RIN 1545–BJ49
United States Property Held by
Controlled Foreign Corporations in
Transactions Involving Partnerships;
Rents and Royalties Derived in the
Active Conduct of a Trade or
Business; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Final and temporary
regulations; correcting amendment.
AGENCY:
This document contains
corrections to final and temporary
regulations (TD 9733) that were
published in the Federal Register on
September 2, 2015 (80 FR 52976). The
temporary regulations are regarding the
treatment as United States property of
SUMMARY:
E:\FR\FM\29OCR1.SGM
29OCR1
66416
Federal Register / Vol. 80, No. 209 / Thursday, October 29, 2015 / Rules and Regulations
property held by a controlled foreign
corporation in connection with certain
transactions involving partnerships.
DATES: This correction is effective on
October 29, 2015 and applicable
beginning September 2, 2015.
FOR FURTHER INFORMATION CONTACT: Rose
E. Jenkins at (202) 317–6934 (not a toll
free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations
(TD 9733) that are the subject of this
correction are under sections 954 and
956 of the Internal Revenue Code.
Need for Correction
As published, the final and temporary
regulations (TD 9733) contain errors that
may prove to be misleading and are in
need of clarification.
guidance, see § 1.954–2(d)(2)(iii)
introductory text through (d)(2)(iii)(D).
*
*
*
*
*
(j) * * * See § 1.954–2(c)(1)(i),
(c)(1)(iv), (c)(2)(ii), (c)(2)(iii), (d)(1)(i),
(d)(1)(ii), (d)(2)(ii), and (d)(2)(iii), as
contained in 26 CFR part 1 revised as of
April 1, 2015, for rules applicable to
rents or royalties, as applicable,
received or accrued before September 1,
2015.
*
*
*
*
*
■ Par. 3. Section 1.956–1 is amended by
revising paragraph (g) introductory text
through (g)(3) to read as follows:
§ 1.956–1 Shareholder’s pro rata share of
a controlled foreign corporation’s increase
in earnings invested in United States
property.
PART 1—INCOME TAXES
*
*
*
*
(g) introductory text through (g)(3)
[Reserved]. For further guidance, see
§ 1.956–1T(g) introductory text through
(g)(3).
*
*
*
*
*
■ Par. 4. Section 1.956–1T is amended
by revising paragraph (b)(4)(ii), the third
sentence of paragraph (b)(4)(iv) Example
1. (i), the first sentence of paragraph
(b)(4)(iv) Example 3. (i), and paragraph
(g)(1) to read as follows:
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
§ 1.956–1T Shareholder’s pro rata share of
a controlled foreign corporation’s increase
in earnings invested in United States
property (temporary).
26 CFR Part 1
*
RIN 1545–BJ49
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
■
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.954–2T is amended
by revising paragraph (a)(1) through
(c)(1) introductory text, paragraph
(c)(2)(iii) introductory text through
(c)(2)(iii)(D), paragraph (c)(3) and (d)(1)
introductory text, (d)(2)(iii) introductory
text through (d)(2)(iii)(D), and the last
sentence of paragraph (j) to read as
follows:
■
rmajette on DSK7SPTVN1PROD with RULES
§ 1.954–3T Foreign personal holding
company income (temporary).
(a)(1) through (c)(1) introductory text
[Reserved]. For further guidance, see
§ 1.954–2(a)(1) through (c)(1)
introductory text.
*
*
*
*
*
(c)(2)(iii) introductory text through
(c)(2)(iii)(D) [Reserved]. For further
guidance, see § 1.954–2(c)(2)(iii)
introductory text through (c)(2)(iii)(D).
*
*
*
*
*
(c)(3) and (d)(1) introductory text
[Reserved]. For further guidance, see
§ 1.954–2(c)(3) and (d)(1) introductory
text.
*
*
*
*
*
(d)(2)(iii) introductory text through
(d)(2)(iii)(D) [Reserved]. For further
VerDate Sep<11>2014
13:13 Oct 28, 2015
Jkt 238001
*
(g) * * * (1) Paragraph (b)(4) of this
section applies to taxable years of
controlled foreign corporations ending
on or after September 1, 2015, and to
taxable years of United States
shareholders in which or with which
such taxable years end, with respect to
property acquired on or after September
1, 2015. See paragraph (b)(4) of § 1.956–
1T, as contained in 26 CFR part 1
revised as of April 1, 2015, for the rules
applicable to taxable years of controlled
foreign corporations ending before
September 1, 2015, and property
acquired before September 1, 2015. For
purposes of this paragraph (g)(1), a
deemed exchange of property pursuant
to section 1001 on or after September 1,
2015, constitutes an acquisition of the
property on or after that date.
*
*
*
*
*
*
*
*
*
(b) * * *
(4) * * *
(ii) Control. For purposes of
paragraphs (b)(4)(i)(B) and (C) of this
section, a controlled foreign corporation
controls a foreign corporation or
partnership if the controlled foreign
corporation and the other foreign
corporation or partnership are related
within the meaning of section 267(b) or
section 707(b). For this purpose, in
determining whether two corporations
are members of the same controlled
group under section 267(b)(3), a person
is considered to own stock owned
directly by such person, stock owned for
the purposes of section 1563(e)(1), and
stock owned with the application of
section 267(c).
*
*
*
*
*
(iv) * * *
Example 1. (i) * * * FS2 has no earnings
and profits, and FS1 has substantial
accumulated earnings and profits. * * *
*
*
*
*
*
Example 3. (i) * * * FS1 has $100x of
post-1986 undisturbed earnings and profits
and $100x post-1986 foreign income taxes,
but does not have any cash. * * *
*
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*
*
Frm 00004
*
Fmt 4700
*
Sfmt 4700
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2015–27603 Filed 10–28–15; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
[TD 9733]
United States Property Held by
Controlled Foreign Corporations in
Transactions Involving Partnerships;
Rents and Royalties Derived in the
Active Conduct of a Trade or
Business; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Final and temporary
regulations; correction.
AGENCY:
This document contains
corrections to final and temporary
regulations (TD 9733) that were
published in the Federal Register on
September 2, 2015 (80 FR 52976). The
temporary regulations are regarding the
treatment as United States property of
property held by a controlled foreign
corporation in connection with certain
transactions involving partnerships.
DATES: This correction is effective on
October 29, 2015 and applicable
beginning September 2, 2015.
FOR FURTHER INFORMATION CONTACT: Rose
E. Jenkins at (202) 317–6934 (not a toll
free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
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]]>Agencies
[Federal Register Volume 80, Number 209 (Thursday, October 29, 2015)]
[Rules and Regulations]
[Pages 66415-66416]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-27603]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9733]
RIN 1545-BJ49
United States Property Held by Controlled Foreign Corporations in
Transactions Involving Partnerships; Rents and Royalties Derived in the
Active Conduct of a Trade or Business; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final and temporary regulations; correcting amendment.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to final and temporary
regulations (TD 9733) that were published in the Federal Register on
September 2, 2015 (80 FR 52976). The temporary regulations are
regarding the treatment as United States property of
[[Page 66416]]
property held by a controlled foreign corporation in connection with
certain transactions involving partnerships.
DATES: This correction is effective on October 29, 2015 and applicable
beginning September 2, 2015.
FOR FURTHER INFORMATION CONTACT: Rose E. Jenkins at (202) 317-6934 (not
a toll free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations (TD 9733) that are the subject
of this correction are under sections 954 and 956 of the Internal
Revenue Code.
Need for Correction
As published, the final and temporary regulations (TD 9733) contain
errors that may prove to be misleading and are in need of
clarification.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following
correcting amendments:
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 * * *
0
Par. 2. Section 1.954-2T is amended by revising paragraph (a)(1)
through (c)(1) introductory text, paragraph (c)(2)(iii) introductory
text through (c)(2)(iii)(D), paragraph (c)(3) and (d)(1) introductory
text, (d)(2)(iii) introductory text through (d)(2)(iii)(D), and the
last sentence of paragraph (j) to read as follows:
Sec. 1.954-3T Foreign personal holding company income (temporary).
(a)(1) through (c)(1) introductory text [Reserved]. For further
guidance, see Sec. 1.954-2(a)(1) through (c)(1) introductory text.
* * * * *
(c)(2)(iii) introductory text through (c)(2)(iii)(D) [Reserved].
For further guidance, see Sec. 1.954-2(c)(2)(iii) introductory text
through (c)(2)(iii)(D).
* * * * *
(c)(3) and (d)(1) introductory text [Reserved]. For further
guidance, see Sec. 1.954-2(c)(3) and (d)(1) introductory text.
* * * * *
(d)(2)(iii) introductory text through (d)(2)(iii)(D) [Reserved].
For further guidance, see Sec. 1.954-2(d)(2)(iii) introductory text
through (d)(2)(iii)(D).
* * * * *
(j) * * * See Sec. 1.954-2(c)(1)(i), (c)(1)(iv), (c)(2)(ii),
(c)(2)(iii), (d)(1)(i), (d)(1)(ii), (d)(2)(ii), and (d)(2)(iii), as
contained in 26 CFR part 1 revised as of April 1, 2015, for rules
applicable to rents or royalties, as applicable, received or accrued
before September 1, 2015.
* * * * *
0
Par. 3. Section 1.956-1 is amended by revising paragraph (g)
introductory text through (g)(3) to read as follows:
Sec. 1.956-1 Shareholder's pro rata share of a controlled foreign
corporation's increase in earnings invested in United States property.
* * * * *
(g) introductory text through (g)(3) [Reserved]. For further
guidance, see Sec. 1.956-1T(g) introductory text through (g)(3).
* * * * *
0
Par. 4. Section 1.956-1T is amended by revising paragraph (b)(4)(ii),
the third sentence of paragraph (b)(4)(iv) Example 1. (i), the first
sentence of paragraph (b)(4)(iv) Example 3. (i), and paragraph (g)(1)
to read as follows:
Sec. 1.956-1T Shareholder's pro rata share of a controlled foreign
corporation's increase in earnings invested in United States property
(temporary).
* * * * *
(b) * * *
(4) * * *
(ii) Control. For purposes of paragraphs (b)(4)(i)(B) and (C) of
this section, a controlled foreign corporation controls a foreign
corporation or partnership if the controlled foreign corporation and
the other foreign corporation or partnership are related within the
meaning of section 267(b) or section 707(b). For this purpose, in
determining whether two corporations are members of the same controlled
group under section 267(b)(3), a person is considered to own stock
owned directly by such person, stock owned for the purposes of section
1563(e)(1), and stock owned with the application of section 267(c).
* * * * *
(iv) * * *
Example 1. (i) * * * FS2 has no earnings and profits, and FS1
has substantial accumulated earnings and profits. * * *
* * * * *
Example 3. (i) * * * FS1 has $100x of post-1986 undisturbed
earnings and profits and $100x post-1986 foreign income taxes, but
does not have any cash. * * *
* * * * *
(g) * * * (1) Paragraph (b)(4) of this section applies to taxable
years of controlled foreign corporations ending on or after September
1, 2015, and to taxable years of United States shareholders in which or
with which such taxable years end, with respect to property acquired on
or after September 1, 2015. See paragraph (b)(4) of Sec. 1.956-1T, as
contained in 26 CFR part 1 revised as of April 1, 2015, for the rules
applicable to taxable years of controlled foreign corporations ending
before September 1, 2015, and property acquired before September 1,
2015. For purposes of this paragraph (g)(1), a deemed exchange of
property pursuant to section 1001 on or after September 1, 2015,
constitutes an acquisition of the property on or after that date.
* * * * *
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2015-27603 Filed 10-28-15; 8:45 am]
BILLING CODE 4830-01-P
