Exclusion of Foreign Currency Gain or Loss Related to Business Needs From Foreign Personal Holding Company Income; Mark-to-Market Method of Accounting for Section 988 Transactions; Correction, 61199 [2017-27865]
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Federal Register / Vol. 82, No. 247 / Wednesday, December 27, 2017 / Proposed Rules
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NW, Washington, DC 20240.
Dated: October 19, 2017.
John Tahsuda,
Principal Deputy Assistant Secretary—Indian
Affairs, Exercising the Authority of the
Assistant Secretary—Indian Affairs.
[FR Doc. 2017–27668 Filed 12–26–17; 8:45 am]
BILLING CODE 4337–15–P
notice of proposed rulemaking at 82 FR
60135, December 19, 2017, are still
being accepted and must be received by
March 19, 2018.
ADDRESSES: Send submissions to
CC:PA:LPD:PR (REG–119514–15), Room
5203, Internal Revenue Service, P.O.
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–119514–
15), Courier’s desk, Internal Revenue
Service, 1111 Constitution Avenue NW,
Washington, DC 20224, or sent
electronically, via the Federal
eRulemaking Portal at
www.regulations.gov (IRS REG–119514–
15).
FOR FURTHER INFORMATION CONTACT:
Jeffery G. Mitchell, (202) 317–6934 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
61199
center CFC’s foreign currency gains and
losses under a variety of theories. No
inference is intended in these proposed
regulations as to whether these
positions are permissible in the years
prior to the application of these
proposed regulations.’’
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel, Procedure and Administration.
[FR Doc. 2017–27865 Filed 12–26–17; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE INTERIOR
National Park Service
36 CFR Part 7
Background
[NPS–PWR–GOGA–24579; PPPWGOGAPO,
PPMPSPD1Z.YM0000]
26 CFR Part 1
The proposed regulations that are the
subject of this correction are under
sections 446, 954 and 988 of the Internal
Revenue Code.
Withdrawal of Proposed Rule for Dog
Management at the Golden Gate
National Recreation Area, California
[REG–119514–15]
Need for Correction
AGENCY:
DEPARTMENT OF THE TREASURY
Internal Revenue Service
RIN 1545–BM80
Exclusion of Foreign Currency Gain or
Loss Related to Business Needs From
Foreign Personal Holding Company
Income; Mark-to-Market Method of
Accounting for Section 988
Transactions; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking;
correction.
AGENCY:
This document contains
corrections to the proposed regulations
(REG–119514–15) that were published
in the Federal Register on Tuesday,
December 19, 2017. The proposed
regulations provide guidance on the
treatment of foreign currency gain or
loss of a controlled foreign corporation
(CFC) under the business needs
exclusion from foreign personal holding
company income (FPHCI). The
proposed regulations also provide an
election for a taxpayer to use a mark-tomarket method of accounting for foreign
currency gain or loss attributable to
section 988 transactions. In addition,
the proposed regulations permit the
controlling United States shareholders
of a CFC to automatically revoke certain
elections concerning the treatment of
foreign currency gain or loss.
DATES: Written or electronic comments
and requests for a public hearing, for the
daltland on DSKBBV9HB2PROD with PROPOSALS
SUMMARY:
VerDate Sep<11>2014
20:10 Dec 26, 2017
Jkt 244001
As published, the proposed
regulations contain errors which may
prove to be misleading and need to be
clarified.
Correction of Publication
Accordingly, the proposed regulations
(REG–119514–15) that are the subject of
FR Doc. 2017–27320 are corrected as
follows:
On page 60138, in the preamble, first
column, the first full paragraph is
corrected to read:
‘‘Although the borrowing and lending
in the same nonfunctional currency are
economically offsetting, section 475
creates the potential for a mismatch of
gains and losses for a treasury center
CFC. If the treasury center CFC qualifies
as a dealer under section 475, for
example because it regularly purchases
debt from related CFCs in the ordinary
course of a trade or business, the
treasury center CFC generally must use
a mark-to-market method of accounting
for its securities. See section 475 and
§ 1.475(c)–1(a)(3)(i). However,
§ 1.475(c)–2(a)(2) provides that a
dealer’s own issued debt liabilities are
not securities for purposes of section
475. Consequently, a treasury center
CFC that marks to market its assets but
not its liabilities may recognize any
offsetting foreign currency gains and
losses in different taxable years. To
avoid this mismatch, taxpayers have
taken positions that match a treasury
PO 00000
Frm 00008
Fmt 4702
Sfmt 9990
ACTION:
National Park Service, Interior.
Withdrawal of proposed rule.
The National Park Service
(NPS) no longer intends to prepare a
final rule or issue a Golden Gate
National Recreation Area dog
management plan. The NPS has
terminated the rulemaking process.
SUMMARY:
The proposed rule is withdrawn
as of December 27, 2017.
DATES:
FOR FURTHER INFORMATION CONTACT:
Dana Polk, Public Affairs Office, Park
Headquarters, Fort Mason, Building 201,
San Francisco, CA 94123; phone 415–
561–4728.
Pursuant
to the National Environmental Policy
Act (NEPA) and the regulations
implementing NEPA (40 CFR parts
1500–1508 and 43 CFR part 46), the
NPS published a proposed rule for dog
management on February 24, 2016 (81
FR 9139). The NPS has now cancelled
that planning process and terminated
the associated NEPA and rulemaking
processes. No final rule will be issued.
SUPPLEMENTARY INFORMATION:
Dated: December 19, 2017.
Martha J. Lee,
Acting Regional Director, Pacific West Region.
[FR Doc. 2017–27827 Filed 12–26–17; 8:45 am]
BILLING CODE 4312–52–P
E:\FR\FM\27DEP1.SGM
27DEP1
Agencies
[Federal Register Volume 82, Number 247 (Wednesday, December 27, 2017)]
[Proposed Rules]
[Page 61199]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-27865]
=======================================================================
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-119514-15]
RIN 1545-BM80
Exclusion of Foreign Currency Gain or Loss Related to Business
Needs From Foreign Personal Holding Company Income; Mark-to-Market
Method of Accounting for Section 988 Transactions; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; correction.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to the proposed regulations
(REG-119514-15) that were published in the Federal Register on Tuesday,
December 19, 2017. The proposed regulations provide guidance on the
treatment of foreign currency gain or loss of a controlled foreign
corporation (CFC) under the business needs exclusion from foreign
personal holding company income (FPHCI). The proposed regulations also
provide an election for a taxpayer to use a mark-to-market method of
accounting for foreign currency gain or loss attributable to section
988 transactions. In addition, the proposed regulations permit the
controlling United States shareholders of a CFC to automatically revoke
certain elections concerning the treatment of foreign currency gain or
loss.
DATES: Written or electronic comments and requests for a public
hearing, for the notice of proposed rulemaking at 82 FR 60135, December
19, 2017, are still being accepted and must be received by March 19,
2018.
ADDRESSES: Send submissions to CC:PA:LPD:PR (REG-119514-15), Room 5203,
Internal Revenue Service, P.O. 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-
119514-15), Courier's desk, Internal Revenue Service, 1111 Constitution
Avenue NW, Washington, DC 20224, or sent electronically, via the
Federal eRulemaking Portal at www.regulations.gov (IRS REG-119514-15).
FOR FURTHER INFORMATION CONTACT: Jeffery G. Mitchell, (202) 317-6934
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The proposed regulations that are the subject of this correction
are under sections 446, 954 and 988 of the Internal Revenue Code.
Need for Correction
As published, the proposed regulations contain errors which may
prove to be misleading and need to be clarified.
Correction of Publication
Accordingly, the proposed regulations (REG-119514-15) that are the
subject of FR Doc. 2017-27320 are corrected as follows:
On page 60138, in the preamble, first column, the first full
paragraph is corrected to read:
``Although the borrowing and lending in the same nonfunctional
currency are economically offsetting, section 475 creates the potential
for a mismatch of gains and losses for a treasury center CFC. If the
treasury center CFC qualifies as a dealer under section 475, for
example because it regularly purchases debt from related CFCs in the
ordinary course of a trade or business, the treasury center CFC
generally must use a mark-to-market method of accounting for its
securities. See section 475 and Sec. 1.475(c)-1(a)(3)(i). However,
Sec. 1.475(c)-2(a)(2) provides that a dealer's own issued debt
liabilities are not securities for purposes of section 475.
Consequently, a treasury center CFC that marks to market its assets but
not its liabilities may recognize any offsetting foreign currency gains
and losses in different taxable years. To avoid this mismatch,
taxpayers have taken positions that match a treasury center CFC's
foreign currency gains and losses under a variety of theories. No
inference is intended in these proposed regulations as to whether these
positions are permissible in the years prior to the application of
these proposed regulations.''
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel, Procedure and Administration.
[FR Doc. 2017-27865 Filed 12-26-17; 8:45 am]
BILLING CODE 4830-01-P