User Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents, 58202-58206 [2018-25210]

Agencies

• Internal Revenue Service
• DEPARTMENT OF THE TREASURY

[Federal Register Volume 83, Number 223 (Monday, November 19, 2018)]
[Proposed Rules]
[Pages 58202-58206]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-25210]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 300

[REG-122898-17]
RIN 1545-BO38


User Fees Relating to Enrolled Agents and Enrolled Retirement 
Plan Agents

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

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SUMMARY: This document contains proposed amendments to the regulations 
relating to imposing user fees for enrolled agents and enrolled 
retirement plan agents. The proposed regulations remove the initial 
enrollment user fee for enrolled retirement plan agents because the IRS 
no longer offers initial enrollment as an enrolled retirement plan 
agent. The proposed regulations also increase the amount of the renewal 
user fee for enrolled retirement plan agents from $30 to $67. In 
addition, the proposed regulations increase the amount of both the 
enrollment and renewal user fee for enrolled agents from $30 to $67. 
The proposed regulations affect individuals who are or apply to become 
enrolled agents and individuals who are enrolled retirement plan 
agents. The Independent Offices Appropriations Act of 1952 authorizes 
charging user fees.

DATES: Written or electronic comments must be received by January 18, 
2019. Requests to speak and outlines of topics to be discussed at the 
public hearing

[[Page 58203]]

scheduled for January 24, 2019, at 10 a.m. must be received by January 
18, 2019.

ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-122898-17), 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-
122898-17), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue NW, Washington, DC 20224 or sent electronically via the Federal 
eRulemaking Portal at https://www.regulations.gov (IRS REG-122898-17). 
The public hearing will be held in the Main Auditorium of the Internal 
Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Mark Shurtliff at (202) 317-6845; concerning cost methodology, Michael 
A. Weber at (202) 803-9738; concerning submission of comments, the 
public hearing, or to be placed on the building access list to attend 
the public hearing, Regina Johnson at (202) 317-6901 (not toll-free 
numbers).

SUPPLEMENTARY INFORMATION: 

Background and Explanation of Provisions

    This document contains proposed amendments to 26 CFR part 300 
regarding user fees.

A. Enrolled Agents and Enrolled Retirement Plan Agents

    Section 330(a)(1) of title 31 of the United States Code authorizes 
the Secretary of the Treasury to regulate the practice of 
representatives before the Treasury Department. Before admitting a 
representative to practice, the Secretary is authorized to ``require 
that the representative demonstrate--(A) good character; (B) good 
reputation; (C) necessary qualifications to enable the representative 
to provide to persons valuable service; and (D) competency to advise 
and assist persons in presenting their cases.'' 31 U.S.C. 330(a)(2). 
Pursuant to section 330 of title 31, the Secretary has published 
regulations governing practice before the IRS in 31 CFR part 10 and 
reprinted the regulations as Treasury Department Circular No. 230 
(Circular 230).
    Section 10.4(a) of Circular 230 authorizes the IRS to grant 
enrollment as enrolled agents to individuals who demonstrate special 
competence in tax matters by passing a written examination administered 
by, or under the oversight of, the IRS and who have not engaged in any 
conduct that would justify suspension or disbarment under Circular 230. 
Every year, the IRS develops and administers an Enrolled Agent Special 
Enrollment Examination (EA-SEE) that individuals must pass to become an 
enrolled agent.
    Section 10.4(b) of Circular 230 currently authorizes the IRS to 
grant enrollment as enrolled retirement plan agents to individuals who 
demonstrate special competence in qualified retirement plan matters by 
passing a written examination administered by, or under the oversight 
of, the IRS and who have not engaged in any conduct that would justify 
suspension or disbarment under Circular 230. Until February 12, 2016, 
the IRS annually developed and administered an Enrolled Retirement Plan 
Agent Special Enrollment Examination (ERPA-SEE) that individuals were 
required to take and pass to become an enrolled retirement plan agent. 
After February 12, 2016, however, the IRS stopped offering the ERPA-
SEE. Individuals who have already passed the ERPA-SEE may maintain 
their enrollment as enrolled retirement plan agents, but the IRS is not 
accepting applications to become new Enrolled Retirement Plan Agents. 
Accordingly, the proposed regulations propose to remove the user fee 
for the initial enrollment of an enrolled retirement plan agent 
currently in Treasury Regulation Sec.  300.10.
    Section 10.4(d) also authorizes the IRS to grant enrollment as an 
enrolled agent or an enrolled retirement plan agent to a qualifying 
former IRS employee by virtue of past IRS service and technical 
experience if the former employee has not engaged in any conduct that 
would justify suspension or disbarment under the provisions of Circular 
230 and meets certain other requirements. Application for enrollment as 
an enrolled agent based on former employment with the IRS must be made 
within three years from the date of separation from that employment and 
does not require passing the EA-SEE. When the IRS discontinued offering 
the ERPA-SEE necessary for enrollment as an enrolled retirement plan 
agent for individuals without IRS work experience, effective February 
12, 2016, the IRS stopped granting individuals enrollment as enrolled 
retirement plan agents by virtue of past service and technical 
experience in the IRS.
    Once eligible for enrollment as an enrolled agent, whether by 
examination or former employment with the IRS, an individual must file 
an application for enrollment with the IRS and currently pay a $30 
nonrefundable user fee. To maintain active enrollment and practice 
before the IRS, an individual who has been enrolled as an enrolled 
agent or enrolled retirement plan agent must file an application to 
renew enrollment every three years and currently pay a $30 
nonrefundable user fee. 31 CFR 10.6(d).
    The IRS Return Preparer Office (RPO) is responsible for certain 
matters related to authority to practice before the IRS, including 
acting on applications for enrollment and renewal of enrolled agents 
and for renewal of enrolled retirement plan agents. 31 CFR 10.1. As a 
condition for enrollment as an enrolled agent, the RPO may conduct a 
federal tax-compliance check to determine whether an applicant has 
filed all required tax returns and has no outstanding federal tax debts 
and a suitability check to determine whether an applicant has engaged 
in any conduct that would justify suspending or disbarring any 
practitioner under Circular 230. 31 CFR 10.5(d). As a condition for 
renewal, enrolled agents and enrolled retirement plan agents must 
certify completion of the continuing education requirements. 31 CFR 
10.6(e).
    As part of its responsibility for administering the enrollment 
program, RPO determines whether applicants have met the above 
requirements. 31 CFR 10.6(j)(1). An applicant who is denied enrollment 
as an enrolled agent for failure to pass a tax-compliance check may 
reapply if the applicant becomes current with respect to the 
applicant's tax liabilities. 31 CFR 10.5(d)(2). Applicants who fail to 
meet the continuing education and fee payment requirements receive from 
RPO a notice that states the basis for RPO's determination of 
noncompliance and provides an opportunity to cure the failure. 31 CFR 
10.6(j)(1).

B. User Fee Authority

    The Independent Offices Appropriations Act of 1952 (IOAA) (31 
U.S.C. 9701) authorizes each agency to promulgate regulations 
establishing the charge for services the agency provides (user fees). 
Under the IOAA, these user-fee regulations are subject to policies 
prescribed by the President and shall be as uniform as practicable. 
Those policies are currently set forth in the Office of Management and 
Budget (OMB) Circular A-25 (OMB Circular), 58 FR 38142 (July 15, 1993).
    The IOAA states that the services provided by an agency should be 
self-sustaining to the extent possible (31 U.S.C. 9701(a)). The OMB 
Circular states that agencies providing services

[[Page 58204]]

that confer special benefits on identifiable recipients beyond those 
accruing to the general public must identify those services, determine 
whether user fees should be assessed for those services, and, if so, 
establish user fees that recover the full cost of providing those 
services. As required by the IOAA and the OMB Circular, agencies are to 
review user fees biennially and update them as necessary to reflect 
changes in the cost of providing the underlying services. During these 
biennial reviews, an agency must calculate the full cost of providing 
each service, taking into account all direct and indirect costs to any 
part of the U.S. government. The full cost of providing a service 
includes, but is not limited to, salaries, retirement benefits, rents, 
utilities, travel, and management costs, as well as an appropriate 
allocation of overhead and other support costs associated with 
providing the service.
    An agency should set the user fee at an amount that recovers the 
full cost of providing the service unless the agency requests, and the 
OMB grants, an exception to the full-cost requirement. The OMB may 
grant exceptions only where the cost of collecting the fees would 
represent an unduly large part of the fee for the activity, or where 
any other condition exists that, in the opinion of the agency head, 
justifies an exception. When the OMB grants an exception, the agency 
does not collect the full cost of providing the service that confers a 
special benefit on identifiable recipients rather than the public at 
large, and the agency therefore must fund the remaining cost of 
providing the service from other available funding sources. When the 
OMB grants an exception, the agency, and by extension all taxpayers, 
subsidize the cost of the service to the recipients who would otherwise 
be required to pay the full cost of providing the service, as the IOAA 
and the OMB Circular direct.

C. Enrollment and Renewal User Fees for the Enrolled Agent and Renewal 
User Fee for the Enrolled Retirement Plan Agent

    As discussed in section A of this preamble, an individual who has 
been granted enrollment as an enrolled agent or an enrolled retirement 
plan agent may practice before the IRS. The IRS confers benefits on 
individuals who are enrolled agents or enrolled retirement plan agents 
beyond those that accrue to the general public by allowing them to 
practice before the IRS. Because the ability to practice before the IRS 
is a special benefit, the IRS charges a user fee to recover the full 
cost associated with administering the program for enrollment and 
renewal of enrolled agents and renewal of enrolled retirement plan 
agents.
    On September 30, 2010, the Treasury Department and the IRS 
published two final regulations in the Federal Register: final 
regulations (TD 9501, 75 FR 60309) that required tax return preparers 
who prepare all or substantially all of a tax return or claim for 
refund for compensation to obtain a preparer tax identification number 
(PTIN) and final regulations (TD 9503, 75 FR 60316) that required a 
user fee to apply for or renew a PTIN. Individuals applying for or 
renewing a PTIN were to be subject to federal tax-compliance and 
suitability checks and were required to pay a $50 user fee to obtain or 
renew a PTIN. All enrolled agents and certain enrolled retirement plan 
agents were required to obtain a PTIN as a condition of enrollment and 
renewal of enrollment. TD 9527, 76 FR 32286; Notice 2011-91, 2011-47 
I.R.B. 792.
    On April 19, 2011, the Treasury Department and the IRS published in 
the Federal Register (76 FR 21805) a final regulation (TD 9523) that 
reduced the amount of the user fees for the initial enrollment and 
renewal enrollment for enrolled agents and enrolled retirement plan 
agents from $125 to $30. Because individuals applying to enroll as an 
enrolled agent or enrolled retirement plan agent also had to obtain a 
PTIN, the user fee to enroll or renew enrollment was reduced to reflect 
that certain review procedures (including federal tax-compliance and 
suitability checks) would be performed as part of the process to obtain 
a PTIN. On June 1, 2017, the IRS ceased collecting any user fees 
related to the PTIN. See Steele v. United States, 260 F.Supp.3d 52 (D. 
D.C. 2017) (holding that the IRS was authorized to require tax return 
preparers to obtain PTINs, but was not authorized to charge fees for 
PTINs).
    As required by the IOAA and the OMB Circular, the RPO completed its 
2017 biennial review of the enrollment and renewal user fees associated 
with enrolled agents and enrolled retirement plan agents. As discussed 
in section D of this preamble, during its review the RPO took into 
account the increase in labor, benefits, and overhead costs incurred in 
connection with providing services to individuals who enroll or renew 
enrollment as enrolled agents and enrolled retirement plan agents since 
the user fee was last changed in 2011. In addition, RPO determined that 
costs associated with federal tax-compliance checks and suitability 
checks on enrolled individuals should be recovered as part of the user 
fee for administering the enrollment and renewal programs. The 2017 
biennial review also took into account new costs associated with 
administering the program for enrolled agents and enrolled retirement 
plan agents, including the costs of operating a dedicated toll-free 
helpline in the RPO for enrollment and renewal matters. The RPO 
determined that the full cost of administering the program for enrolled 
agents and enrolled retirement plan agents has increased from $30 to 
$67 per application for enrollment or renewal. The proposed fee 
complies with the directive in the OMB Circular to recover the full 
cost of providing a service that confers special benefits on 
identifiable recipients beyond those accruing to the general public.

D. Calculation of User Fees Generally

    The IRS follows generally accepted accounting principles (GAAP) in 
calculating the full cost of processing an application for enrollment 
or renewal. The Federal Accounting Standards Advisory Board (FASAB) is 
the body that establishes GAAP that apply for federal reporting 
entities, such as the IRS. FASAB publishes the FASAB Handbook of 
Accounting Standards and Other Pronouncements, as Amended (Current 
Handbook), which is available at https://files.fasab.gov/pdffiles/2017_fasab_handbook.pdf. The Current Handbook includes the Statement of 
Federal Financial Accounting Standards (SFFAS) No. 4: Managerial Cost 
Accounting Concepts and Standards for the Federal Government. SFFAS No. 
4 establishes internal costing standards under GAAP to accurately 
measure and manage the full cost of federal programs, and the 
methodology below is in accordance with SFFAS No. 4.
1. Cost Center Allocation
    The IRS determines the cost of its services and the activities 
involved in producing them through a cost-accounting system that tracks 
costs to organizational units. The lowest organizational unit in the 
IRS's cost-accounting system is called a cost center. Cost centers are 
usually separate offices that are distinguished by subject-matter area 
of responsibility or geographic region. All costs of operating a cost 
center are recorded in the IRS's cost-accounting system and allocated 
to that cost center. The costs allocated to a cost center are the 
direct costs for the cost center's activities as well as all indirect 
costs, including overhead, associated with that cost center. Each cost 
is recorded in only one cost center.

[[Page 58205]]

2. Determining the per Unit Cost
    To establish the per-unit cost, the total cost of providing the 
service is divided by the volume of services provided.
3. Cost Estimation of Direct Labor
    Not all cost centers are fully devoted to one service for which the 
IRS charges user fees. Some cost centers work on a number of different 
services across the IRS. In these cases, the IRS uses various cost-
measurement techniques to estimate the cost incurred in those cost 
centers attributable to the program. These techniques include using 
various timekeeping systems to measure the time required to accomplish 
activities, or using information provided by subject-matter experts on 
the time devoted to a program. Once the IRS has estimated the average 
time required to accomplish an activity, it multiplies that time 
estimate by the relevant organizational unit's average labor and 
benefits cost per unit of time to determine the labor and benefits cost 
incurred to provide the service. To determine the full cost, IRS then 
adds overhead as discussed below.
4. Overhead
    Overhead is an indirect cost of operating an organization that 
cannot be immediately associated with an activity that the organization 
performs. Overhead includes costs of resources that are jointly or 
commonly consumed by one or more organizational unit's activities but 
are not specifically identifiable to a single activity.
    These costs can include:
     General management and administrative services of 
sustaining and supporting organizations.
     Facilities management and ground maintenance services 
(security, rent, utilities, and building maintenance).
     Procurement and contracting services.
     Financial management and accounting services.
     Information technology services.
     Services to acquire and operate property, plants and 
equipment.
     Publication, reproduction, and graphics and video 
services.
     Research, analytical, and statistical services.
     Human resources/personnel services.
     Library and legal services.
    To calculate the overhead allocable to a service, the IRS 
multiplies a Corporate Overhead rate by the labor and benefits costs 
determined as discussed previously. The IRS calculates the Corporate 
Overhead rate annually based on cost elements underlying the Statement 
of Net Cost included in the IRS Annual Financial Statements, which are 
audited by the Government Accountability Office. The Corporate Overhead 
rate is the ratio of the sum of the IRS's indirect labor and benefits 
costs from the supporting and sustaining organizational units--those 
that do not interact directly with taxpayers--and all non-labor costs 
to the IRS's labor and benefits costs of its organizational units that 
interact directly with taxpayers.
    The Corporate Overhead rate of 68.00 percent for costs reviewed 
during FY 2017 was calculated based on FY 2016 costs (which are assumed 
to be fixed and reoccurring) as follows:

------------------------------------------------------------------------
 
------------------------------------------------------------------------
Indirect Labor and Benefits Costs...................      $1,681,373,747
Non-Labor Costs.....................................     + 2,879,907,032
                                                     -------------------
Total Indirect Costs................................      $4,561,280,779
Direct Labor and Benefits Costs.....................     / 6,708,063,559
                                                     -------------------
Corporate Overhead Rate.............................              68.00%
------------------------------------------------------------------------

E. Calculation of User Fee for Enrolled Agent Enrollment and Renewal 
and Enrolled Retirement Plan Agent Renewal

    The IRS used projections for fiscal years 2018 through 2020 to 
determine the direct costs associated with enrolled agent enrollment 
and renewal and enrolled retirement plan agent renewal. Direct costs 
are incurred by the RPO and include labor costs for enrollment and 
renewal submission processing; tax compliance and background checks; 
continuing education and testing-related activities; and 
communications, which include the new toll-free helpline.
    The labor and benefits for the work performed related to 
applications for enrolled agent enrollment and renewal and enrolled 
retirement plan agent renewal is projected to be $2,708,603 in total 
over fiscal years 2018 through 2020. The labor and benefits costs 
include the cost to perform background checks and tax compliance 
checks, which are services that were not included in the previous $30 
user fee. The number of enrollment and renewal applications is based on 
the FY2016 numbers adjusted by the anticipated increase in enrollment. 
Adding Corporate Overhead expenses to the total labor and benefits 
results in total costs of $4,550,453 as shown below:

------------------------------------------------------------------------
 
------------------------------------------------------------------------
Labor and Benefits.........................................   $2,708,603
Corporate Overhead (68%)...................................    1,841,850
                                                            ------------
Labor, Benefits, and Overhead..............................    4,550,453
------------------------------------------------------------------------

    Dividing this total cost by the projected population of initial 
enrollment and renewal applications for fiscal years 2018 through 2020 
results in a cost per application of $67 as shown below:

------------------------------------------------------------------------
 
------------------------------------------------------------------------
Labor, Benefits and Overhead...............................   $4,550,453
Number of Applications.....................................     / 68,343
                                                            ------------
Cost per Application.......................................           67
------------------------------------------------------------------------

    Taking into account the full amount of these costs, the user fee 
for enrolled agent enrollment or renewal and enrolled retirement plan 
agent renewal is proposed to be $67 per application. The IRS does not 
intend to seek an exception from OMB to the full cost requirement.

Special Analyses

    OIRA has determined that this regulation is significant and subject 
to review under section 6(b) of Executive Order 12866.
    Pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6), it 
is hereby certified that this regulation will not have a significant 
economic impact on a substantial number of small entities. The user fee 
primarily affects individuals who are enrolled agents, apply to become 
enrolled agents, or are enrolled retirement plan agents. Only 
individuals, not businesses, can be enrolled agents or enrolled 
retirement plan agents. Thus, any economic impact of the user fee on 
small entities generally will occur only when an enrolled agent or 
enrolled retirement plan agent owns a small business or when a small 
business employs enrolled agents or enrolled retirement plan agents and 
reimburses them for their renewal fees. The Treasury Department and IRS 
estimate that approximately 22,781 individuals will apply annually for 
enrollment as an enrolled agent, renewal as an enrolled agent, or 
renewal as an enrolled retirement plan agent. Due to the relatively 
small number of small businesses that employ enrolled agents or 
enrolled retirement plan agents, a substantial number of small entities 
are not likely to be affected. Further, the economic impact on any 
small entities affected would be limited to paying the $37 difference 
in cost between the $67 user fee and the previous $30 user fee (for 
each enrolled agent or enrolled retirement plan agent that a small 
entity employs and pays for), which is unlikely to present a 
significant economic impact. The total economic impact of this 
regulation is thus approximately $842,897 annually,

[[Page 58206]]

which is the product of the approximately 22,781 individuals and the 
$37 increase in the fee. Accordingly, the rule is not expected to have 
a significant economic impact on a substantial number of small 
entities, and a regulatory flexibility analysis is not required.
    It is not anticipated that the increase in user fee that is paid 
every three years and averages to $12.33 per year will negatively 
affect enrollment, which has historically remained steady as user fee 
amounts have changed. Pursuant to section 7805(f), this notice of 
proposed rulemaking has 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 amendments to the regulations are adopted as 
final regulations, consideration will be given to any comments that are 
submitted timely to the IRS as prescribed in the preamble under the 
ADDRESSES section. The Treasury Department and the IRS request comments 
on all aspects of the proposed regulations. All comments submitted will 
be made available at www.regulations.gov or upon request.
    A public hearing has been scheduled for January 24, 2019, beginning 
at 10:00 a.m. in the Main Auditorium of the Internal Revenue Service 
Building, 1111 Constitution Avenue NW, Washington, DC 20224. Due to 
building-security procedures, visitors must enter at the Constitution 
Avenue entrance. All visitors must present photo identification to 
enter the building. Because of access restrictions, visitors will not 
be admitted beyond the immediate entrance area 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 Sec.  601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments at the hearing must submit written or 
electronic comments and an outline of the topics to be discussed and 
the time to be devoted to each topic by January 18, 2019. A period of 
10 minutes will be allocated 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 author of these regulations is Mark Shurtliff, Office 
of the Associate Chief Counsel (Procedure and Administration). Other 
personnel from the Treasury Department and the IRS participated in 
their development.

List of Subjects in 26 CFR Part 300

    Reporting and recordkeeping requirements, User fees.

Proposed Amendments to the Regulations

    Accordingly, 26 CFR part 300 is proposed to be amended as follows:

PART 300--USER FEES

0
Paragraph. 1. The authority citation for part 300 continues to read as 
follows:

    Authority: 31 U.S.C. 9701.


Sec.  300.0   [Amended]

0
Par. 2. Section 300.0 is amended by removing paragraph (b)(10) and 
redesignating paragraphs (b)(11) through (13) as paragraphs (b)(10) 
through (12).
0
Par. 3. Section 300.5 is amended by revising paragraphs (b) and (d) to 
read as follows:


Sec.  300.5   Enrollment of enrolled agent fee.

* * * * *
    (b) Fee. The fee for initially enrolling as an enrolled agent with 
the IRS is $67.
* * * * *
    (d) Applicability date. This section applies 30 days after the date 
of publication of a Treasury Decision adopting this rule as a final 
regulation in the Federal Register.
0
Par. 4. Section 300.6 is amended by revising paragraphs (b) and (d) to 
read as follows:


Sec.  300.6  Renewal of enrollment of enrolled agent fee.

* * * * *
    (b) Fee. The fee for renewal of enrollment as an enrolled agent 
with the IRS is $67.
* * * * *
    (d) Applicability date. This section applies 30 days after the date 
of publication of a Treasury Decision adopting this rule as a final 
regulation in the Federal Register.


Sec.  300.10  [Removed]

0
Par. 5. Section 300.10 is removed.


Sec.  300.11  [Redesignated as Sec.  300.10 and Amended]

0
Par. 6. Redesignate Sec.  300.11 as Sec.  300.10 and amend newly 
redesignated Sec.  300.10 by revising paragraphs (b) and (d) to read as 
follows:


Sec.  300.10   Renewal of enrollment of enrolled retirement plan agent 
fee.

* * * * *
    (b) Fee. The fee for renewal of enrollment as an enrolled 
retirement plan agent with the IRS is $67.
* * * * *
    (d) Applicability date. This section applies 30 days after the date 
of publication of a Treasury Decision adopting this rule as a final 
regulation in the Federal Register.


Sec. Sec.  300.12 and 300.13   [Redesignated as Sec. Sec.  300.11 and 
300.12]

0
Par. 7. Redesignate Sec. Sec.  300.12 and 300.13 as Sec. Sec.  300.11 
and 300.12.

Kirsten Wielobob,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2018-25210 Filed 11-15-18; 4:15 pm]
 BILLING CODE 4830-01-P