Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners; Correction, 41885 [2017-18691]

Download as PDF Federal Register / Vol. 82, No. 170 / Tuesday, September 5, 2017 / Rules and Regulations this regulation is consistent with the guidance therein. G. Executive Orders 12372 and 13132: Federalism This regulation will not have substantial direct effects on the States, on the relationship between the national government and the States, or the distribution of power and responsibilities among the various levels of government. Nor will the rule have federalism implications warranting the application of Executive Orders 12372 and 13132. H. Executive Order 13175— Consultation and Coordination With Indian Tribal Governments 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 requirements of section 5 of Executive Order 13175 do not apply to this rulemaking. nonimmigrant may apply for a waiver of the visa and passport requirement if, either prior to the nonimmigrant’s embarkation abroad or upon arrival at a port of entry, the Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP) district director concludes that the nonimmigrant is unable to present the required documents because of an unforeseen emergency. The CBP district director may grant a waiver of the visa or passport requirement pursuant to INA 212(d)(4)(A), without the prior concurrence of the Department of State, if the CBP district director concludes that the nonimmigrant’s claim of emergency circumstances is legitimate and that approval of the waiver would be appropriate under all of the attendant facts and circumstances. * * * * * Carl C. Risch, Assistant Secretary for Consular Affairs, Department of State. [FR Doc. 2017–18750 Filed 9–1–17; 8:45 am] DEPARTMENT OF THE TREASURY List of Subjects in 22 CFR Part 41 26 CFR Part 1 Aliens, Foreign officials, Immigration, Passports and visas, Students. Accordingly, for the reasons set forth in the preamble, 22 CFR part 41 is amended as follows: [TD 9814] PART 41—VISAS—DOCUMENTATION OF NONIMMIGRANTS UNDER THE IMMIGRATION AND NATIONALITY ACT, AS AMENDED 1. The authority citation for part 41 is revised to read as follows: ■ Authority: 22 U.S.C. 2651a; 8 U.S.C. 1104; 8 U.S.C. 1323; Pub. L. 105–277, 112 Stat. 2681–795 through 2681–801; 8 U.S.C. 1185 note (section 7209 of Pub. L. 108–458, as amended by section 546 of Pub. L. 109–295). 2. Section 41.2 is amended by revising paragraph (i) to read as follows: ■ § 41.2 Exemption or waiver by Secretary of State and Secretary of Homeland Security of passport and/or visa requirements for certain categories of nonimmigrants. mstockstill on DSK30JT082PROD with RULES Ronald M. Gootzeit, (202) 317–6937 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The temporary regulations that are the subject of this correction are under section 721(c) of the Code. Need for Correction As published, the temporary regulations contain errors that may prove to be misleading and need to be clarified. 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 Paragraph 1. The authority citation for part 1 continues to read in part as follows: ■ This rule does not impose or revise information collections subject to the provisions of the Paperwork Reduction Act, 44 U.S.C., Chapter 35. * * * * * (i) Individual cases of unforeseen emergencies. Except as provided in paragraphs (a) through (h) and (j) through (l) of this section, all nonimmigrants are required to present a valid, unexpired visa and passport upon arrival in the United States. A 16:52 Sep 01, 2017 FOR FURTHER INFORMATION CONTACT: BILLING CODE 4710–06–P I. Paperwork Reduction Act VerDate Sep<11>2014 41885 Jkt 241001 Authority: 26 U.S.C. 7805 * * * Internal Revenue Service Par. 2. Section 1.721(c)–1T is amended by revising paragraph (b)(10)(vi) to read as follows: ■ RIN 1545–BM95 § 1.721(c)–1T Overview, definitions, and rules of general application (temporary). Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners; Correction * Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regulations; correcting amendment. AGENCY: This document contains corrections to the temporary regulations (T.D. 9814) that were published in the Federal Register on Thursday, January 19, 2017 (82 FR 7582). The regulations address transfers of appreciated property by United States persons to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied. DATES: These corrections are effective on September 5, 2017 and applicable on January 18, 2017. SUMMARY: PO 00000 Frm 00061 Fmt 4700 Sfmt 9990 * * * * (b) * * * (10) * * * (vi) An allocation of partnership level ordinary income or loss described in § 1.751–1(b)(3). * * * * * Par. 3. Section 1.721(c)–6T is amended by revising the last sentence of paragraph (d)(2) to read as follows: ■ § 1.721(c)–6T Procedural and reporting requirements (temporary). * * * * * (d) * * * (2) * * * The partnership must also attach to its Form 1065 a Schedule K– 1 (Form 1065) for each direct or indirect partner that is a related foreign person with respect to the U.S. transferor. * * * * * Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration. [FR Doc. 2017–18691 Filed 9–1–17; 8:45 am] BILLING CODE 4830–01–P E:\FR\FM\05SER1.SGM 05SER1

Agencies

[Federal Register Volume 82, Number 170 (Tuesday, September 5, 2017)]
[Rules and Regulations]
[Page 41885]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-18691]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9814]
RIN 1545-BM95


Transfers of Certain Property by U.S. Persons to Partnerships 
With Related Foreign Partners; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correcting amendment.

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SUMMARY: This document contains corrections to the temporary 
regulations (T.D. 9814) that were published in the Federal Register on 
Thursday, January 19, 2017 (82 FR 7582). The regulations address 
transfers of appreciated property by United States persons to 
partnerships with foreign partners related to the transferor. The 
regulations override the rules providing for nonrecognition of gain on 
a contribution of property to a partnership in exchange for an interest 
in the partnership under section 721(a) of the Internal Revenue Code 
(Code) pursuant to section 721(c) unless the partnership adopts the 
remedial method and certain other requirements are satisfied.

DATES: These corrections are effective on September 5, 2017 and 
applicable on January 18, 2017.

FOR FURTHER INFORMATION CONTACT: Ronald M. Gootzeit, (202) 317-6937 
(not a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The temporary regulations that are the subject of this correction 
are under section 721(c) of the Code.

Need for Correction

    As published, the temporary regulations contain errors that may 
prove to be misleading and need to be clarified.

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 1.721(c)-1T is amended by revising paragraph 
(b)(10)(vi) to read as follows:


Sec.  1.721(c)-1T   Overview, definitions, and rules of general 
application (temporary).

* * * * *
    (b) * * *
    (10) * * *
    (vi) An allocation of partnership level ordinary income or loss 
described in Sec.  1.751-1(b)(3).
* * * * *


0
Par. 3. Section 1.721(c)-6T is amended by revising the last sentence of 
paragraph (d)(2) to read as follows:


Sec.  1.721(c)-6T   Procedural and reporting requirements (temporary).

* * * * *
    (d) * * *
    (2) * * * The partnership must also attach to its Form 1065 a 
Schedule K-1 (Form 1065) for each direct or indirect partner that is a 
related foreign person with respect to the U.S. transferor.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, Procedure and Administration.
[FR Doc. 2017-18691 Filed 9-1-17; 8:45 am]
 BILLING CODE 4830-01-P