Treatment of Certain Transfers of Property to Foreign Corporations; Correction, 52848 [2017-24687]

Download as PDF 52848 Federal Register / Vol. 82, No. 219 / Wednesday, November 15, 2017 / Rules and Regulations standards and practices to determine if it should take action in the future. Paragraph 1. The authority citation for part 1 continues to read in part as follows: ■ By direction of the Commission. Donald S. Clark, Secretary. Authority: 26 U.S.C. 7805 * * * [FR Doc. 2017–24728 Filed 11–14–17; 8:45 am] Par. 2. Section 1.367(a)–1 is amended by adding paragraph (e) to read as follows: ■ BILLING CODE 6750–01–P § 1.367(a)–1 Transfers to foreign corporations subject to section 367(a): In general. DEPARTMENT OF THE TREASURY Internal Revenue Service * 26 CFR Part 1 [TD 9803] RIN 1545–BL87 Treatment of Certain Transfers of Property to Foreign Corporations; Correction Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. AGENCY: This document contains corrections to final regulations (TD 9803) that were published in the Federal Register on Friday, December 16, 2016. The final regulations are related to certain transfers of property by United States persons to foreign corporations. SUMMARY: This correction is effective on November 15, 2017 and is applicable on or after December 16, 2016. FOR FURTHER INFORMATION CONTACT: Lynlee Baker at (202) 317–6937 (not a toll-free number). SUPPLEMENTARY INFORMATION: DATES: Background The final regulations (TD 9803) that are the subject of this correction are issued under section 367 of the Internal Revenue Code. Need for Correction sradovich on DSK3GMQ082PROD with RULES 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 amendment: 15:48 Nov 14, 2017 * * * * (e) Close of taxable year in certain section 368(a)(1)(F) reorganizations. If a domestic corporation is the transferor corporation in a reorganization described in section 368(a)(1)(F) after March 30, 1987, in which the acquiring corporation is a foreign corporation, then the taxable year of the transferor corporation shall end with the close of the date of the transfer and the taxable year of the acquiring corporation shall end with the close of the date on which the transferor’s taxable year would have ended but for the occurrence of the transfer. With regard to the consequences of the closing of the taxable year, see section 381 and the regulations thereunder. * * * * * Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. 2017–24687 Filed 11–14–17; 8:45 am] BILLING CODE 4830–01–P PENSION BENEFIT GUARANTY CORPORATION 29 CFR Part 4022 Benefits Payable in Terminated SingleEmployer Plans; Interest Assumptions for Paying Benefits Pension Benefit Guaranty Corporation. ACTION: Final rule. AGENCY: As published, the final regulations published in the Federal Register on Friday, December 16, 2016 (81 FR 91012) (TD 9803) contain an error that needs to be corrected. Specifically, paragraph (e) was inadvertently omitted from the final regulations. VerDate Sep<11>2014 FOR FURTHER INFORMATION CONTACT: PART 1—INCOME TAXES Jkt 244001 This final rule amends the Pension Benefit Guaranty Corporation’s regulation on Benefits Payable in Terminated Single-Employer Plans to prescribe interest assumptions under the regulation for valuation dates in December 2017. The interest assumptions are used for paying benefits under terminating singleemployer plans covered by the pension insurance system administered by PBGC. SUMMARY: DATES: PO 00000 Effective December 1, 2017. Frm 00026 Fmt 4700 Sfmt 4700 Daniel S. Liebman (liebman.daniel@ pbgc.gov), Acting Assistant General Counsel for Regulatory Affairs, Pension Benefit Guaranty Corporation, 1200 K Street NW., Washington, DC 20005, 202–326–4400 ext. 6510. (TTY/TDD users may call the Federal relay service toll-free at 1–800–877–8339 and ask to be connected to 202–326–4400, ext. 6510.) PBGC’s regulation on Benefits Payable in Terminated Single-Employer Plans (29 CFR part 4022) prescribes actuarial assumptions—including interest assumptions—for paying plan benefits under terminated single-employer plans covered by title IV of the Employee Retirement Income Security Act of 1974. The interest assumptions in the regulation are also published on PBGC’s Web site (http://www.pbgc.gov). PBGC uses the interest assumptions in appendix B to part 4022 to determine whether a benefit is payable as a lump sum and to determine the amount to pay. Appendix C to part 4022 contains interest assumptions for private-sector pension practitioners to refer to if they wish to use lump-sum interest rates determined using PBGC’s historical methodology. Currently, the rates in appendices B and C of the benefit payment regulation are the same. The interest assumptions are intended to reflect current conditions in the financial and annuity markets. Assumptions under the benefit payments regulation are updated monthly. This final rule updates the benefit payments interest assumptions for December 2017.1 The December 2017 interest assumptions under the benefit payments regulation will be 0.75 percent for the period during which a benefit is in pay status and 4.00 percent during any years preceding the benefit’s placement in pay status. In comparison with the interest assumptions in effect for November 2017, these assumptions are unchanged. PBGC has determined that notice and public comment on this amendment are impracticable and contrary to the public interest. This finding is based on the need to determine and issue new interest assumptions promptly so that the assumptions can reflect current market conditions as accurately as possible. SUPPLEMENTARY INFORMATION: 1 Appendix B to PBGC’s regulation on Allocation of Assets in Single-Employer Plans (29 CFR part 4044) prescribes interest assumptions for valuing benefits under terminating covered single-employer plans for purposes of allocation of assets under ERISA section 4044. Those assumptions are updated quarterly. E:\FR\FM\15NOR1.SGM 15NOR1

Agencies

[Federal Register Volume 82, Number 219 (Wednesday, November 15, 2017)]
[Rules and Regulations]
[Page 52848]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-24687]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9803]
RIN 1545-BL87


Treatment of Certain Transfers of Property to Foreign 
Corporations; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to final regulations (TD 
9803) that were published in the Federal Register on Friday, December 
16, 2016. The final regulations are related to certain transfers of 
property by United States persons to foreign corporations.

DATES: This correction is effective on November 15, 2017 and is 
applicable on or after December 16, 2016.

FOR FURTHER INFORMATION CONTACT: Lynlee Baker at (202) 317-6937 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9803) that are the subject of this 
correction are issued under section 367 of the Internal Revenue Code.

Need for Correction

    As published, the final regulations published in the Federal 
Register on Friday, December 16, 2016 (81 FR 91012) (TD 9803) contain 
an error that needs to be corrected. Specifically, paragraph (e) was 
inadvertently omitted from the final regulations.

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 amendment:

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 1.367(a)-1 is amended by adding paragraph (e) to read 
as follows:


Sec.  1.367(a)-1   Transfers to foreign corporations subject to section 
367(a): In general.

* * * * *
    (e) Close of taxable year in certain section 368(a)(1)(F) 
reorganizations. If a domestic corporation is the transferor 
corporation in a reorganization described in section 368(a)(1)(F) after 
March 30, 1987, in which the acquiring corporation is a foreign 
corporation, then the taxable year of the transferor corporation shall 
end with the close of the date of the transfer and the taxable year of 
the acquiring corporation shall end with the close of the date on which 
the transferor's taxable year would have ended but for the occurrence 
of the transfer. With regard to the consequences of the closing of the 
taxable year, see section 381 and the regulations thereunder.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2017-24687 Filed 11-14-17; 8:45 am]
 BILLING CODE 4830-01-P