Rules Regarding Certain Hybrid Arrangements; Hearing, 8488-8489 [2019-04203]

Download as PDF 8488 Federal Register / Vol. 84, No. 46 / Friday, March 8, 2019 / Proposed Rules DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG–132881–17] RIN 1545–BO30 Regulations Reducing Burden Under FATCA and Chapter 3; Hearing Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking; notice of hearing. AGENCY: This document provides a notice of public hearing on proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign pass thru payments, eliminating withholding on certain insurance premiums, and clarifying the definition of investment entity. SUMMARY: The public hearing is being held on Wednesday, April 10, 2019, at 10 a.m. The IRS must receive speakers’ outlines of the topics to be discussed at the public hearing by Friday, March 29, 2019. ADDRESSES: The public hearing is being held in the IRS Auditorium, Internal Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC 20224. Due to building security procedures, visitors must enter at the Constitution Avenue entrance. In addition, all visitors must present a valid photo identification to enter the building. Send Submissions to CC:PA:LPD:PR (REG–132881–17), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be handdelivered Monday through Friday to CC:PA:LPD:PR (REG–132881–17), Couriers 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–132881– 17). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, John Sweeney, Nancy Lee, or Subin Seth, (202) 317–6942; concerning submissions of comments, the hearing and/or to be placed on the building access list to attend the hearing, Regina Johnson, (202) 317–6901 (not toll free numbers) or fdms.database@ irscounsel.treas.gov. DATES: The subject of the public hearing is the SUPPLEMENTARY INFORMATION: VerDate Sep<11>2014 16:08 Mar 07, 2019 Jkt 247001 notice of proposed rulemaking (REG– 132881–17) that was published in the Federal Register on Tuesday, December 18, 2018 (83 FR 64757). The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing that submitted written comments by February 19, 2019, must submit an outline of the topics to be addressed and the amount of time to be devoted to each topic by Friday, March 29, 2019. A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made available, free of charge, at the hearing or by contacting the Publications and Regulations Branch at (202) 317–6901 (not a toll-free number). Because of access restrictions, the IRS will not admit visitors 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 document. Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration). [FR Doc. 2019–04164 Filed 3–7–19; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 301 [REG–104352–18] RIN 1545–BO53 Rules Regarding Certain Hybrid Arrangements; Hearing Internal Revenue Service (IRS), Treasury. ACTION: Proposed rule; notice of hearing. AGENCY: This document provides a notice of public hearing on proposed regulations to implement sections 245A(e) and 267A of the Internal Revenue Code (Code) regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities, and to provide rules under sections 1503(d) and 7701 of the Code to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign country. SUMMARY: PO 00000 Frm 00013 Fmt 4702 Sfmt 4702 The public hearing is being held on Wednesday, March 20, 2019, at 10 a.m. The IRS must receive speakers’ outlines of the topics to be discussed at the public hearing by Friday, March 15, 2019. ADDRESSES: The public hearing is being held in the IRS Auditorium, Internal Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC 20224. Due to building security procedures, visitors must enter at the Constitution Avenue entrance. In addition, all visitors must present a valid photo identification to enter the building. Send Submissions to CC:PA:LPD:PR (REG–104352–18), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be handdelivered Monday through Friday to CC:PA:LPD:PR (REG–104352–18), Couriers 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–104352– 18). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, contact Tracy Villecco at (202) 317– 3800; concerning submissions of comments, the hearing and/or to be placed on the building access list to attend the hearing, Regina L. Johnson at (202) 317–6901 (not toll free numbers) or fdms.database@irscounsel.treas.gov. SUPPLEMENTARY INFORMATION: The subject of the public hearing is the notice of proposed rulemaking (REG– 104352–18) that was published in the Federal Register on Friday, December 28, 2018 (83 FR 67612). The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing that submitted written comments by February 26, 2019, must submit an outline of the topics to be addressed and the amount of time to be devoted to each topic by Friday, March 15, 2019. A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made available, free of charge, at the hearing or by contacting the Publications and Regulations Branch at (202) 317–6901(not a toll-free number). Because of access restrictions, the IRS will not admit visitors beyond the immediate entrance area more than 30 minutes before the hearing starts. For DATES: E:\FR\FM\08MRP1.SGM 08MRP1 Federal Register / Vol. 84, No. 46 / Friday, March 8, 2019 / Proposed Rules information about having your name placed on the building access list to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section of this document. Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. 2019–04203 Filed 3–7–19; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG–2018–1084] RIN 1625–AA00 Safety Zone; Cocos Lagoon, Merizo, GU Coast Guard, DHS. Notice of proposed rulemaking. AGENCY: ACTION: The Coast Guard is proposing to establish a temporary safety zone for navigable waters within Cocos Lagoon. This safety zone will encompass the designated swim course for the Cocos Crossing swim event in the waters of Cocos Lagoon, Merizo, Guam. We invite your comments on this proposed rulemaking. SUMMARY: II. Background, Purpose, and Legal Basis The Cocos Crossing swim event is a recurring annual event that occurs one day either at the end of May or the beginning of June. We have established safety zones for this swim event in past years. The purpose of this rule is to ensure the safety of the participants and the navigable waters in the safety zone before, during, and after the scheduled swim event. The Coast Guard is proposing this rulemaking under authority in 33 U.S.C. 1231. III. Discussion of Proposed Rule The Captain of the Port (COTP) is proposing to establish a safety zone from 6 a.m. to 1 p.m. on a day to be determined to host the Cocos Crossing swimming event either during the last two weeks of May or the first two weeks of June. This safety zone is necessary to protect all persons and vessels participating in this marine event from potential safety hazards associated with vessel traffic in the area. Race participants, chase boats, and organizers of the event will be exempt from the safety zone. Entry of persons or vessels into this safety zone is prohibited unless authorized by the COTP. The regulatory text we are proposing appears at the end of this document. DATES: IV. Regulatory Analyses We developed this proposed rule after considering numerous statutes and Executive orders related to rulemaking. Below we summarize our analyses based on a number of these statutes and Executive orders, and we discuss First Amendment rights of protestors. If you have questions about this proposed rulemaking, call or email Chief Petty Officer Todd Wheeler, Sector Guam, U.S. Coast Guard, by telephone at (671) 355–4866, or email at WWMGuam@ uscg.mil. A. Regulatory Planning and Review Executive Orders 12866 and 13563 direct agencies to assess the costs and benefits of available regulatory alternatives and, if regulation is necessary, to select regulatory approaches that maximize net benefits. Executive Order 13771 directs agencies to control regulatory costs through a budgeting process. This NPRM has not been designated a ‘‘significant regulatory action’’ under Executive Order 12866. Accordingly, the NPRM has not been reviewed by the Office of Management and Budget (OMB), and pursuant to OMB guidance it is exempt from the requirements of Executive Order 13771. This regulatory action determination is based on the size, location, duration, and time-of-day of the safety zone. Vessel traffic will be able to safely transit around this safety zone, which will impact a small designated area of Comments and related material must be received by the Coast Guard on or before April 8, 2019. ADDRESSES: You may submit comments identified by docket number USCG– 2018–1084 using the Federal eRulemaking Portal at https:// www.regulations.gov. See the ‘‘Public Participation and Request for Comments’’ portion of the SUPPLEMENTARY INFORMATION section for further instructions on submitting comments. FOR FURTHER INFORMATION CONTACT: SUPPLEMENTARY INFORMATION: I. Table of Abbreviations CFR Code of Federal Regulations DHS Department of Homeland Security FR Federal Register NPRM Notice of proposed rulemaking § Section U.S.C. United States Code VerDate Sep<11>2014 16:08 Mar 07, 2019 Jkt 247001 PO 00000 Frm 00014 Fmt 4702 Sfmt 4702 8489 the Cocos Lagoon for approximately 7 hours. Moreover, the Coast Guard will issue a Broadcast Notice to Mariners via VHF–FM marine channel 16 about the zone, and the rule allows vessels to seek permission to enter the zone. B. Impact on Small Entities The Regulatory Flexibility Act of 1980, 5 U.S.C. 601–612, as amended, requires Federal agencies to consider the potential impact of regulations on small entities during rulemaking. The term ‘‘small entities’’ comprises small businesses, not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with populations of less than 50,000. The Coast Guard certifies under 5 U.S.C. 605(b) that this proposed rule would not have a significant economic impact on a substantial number of small entities. While some owners or operators of vessels intending to transit the safety zone may be small entities, for the reasons stated in section IV.A above, this proposed rule would not have a significant economic impact on any vessel owner or operator. If you think that your business, organization, or governmental jurisdiction qualifies as a small entity and that this rule would have a significant economic impact on it, please submit a comment (see ADDRESSES) explaining why you think it qualifies, and how and to what degree this rule would economically affect it. Under section 213(a) of the Small Business Regulatory Enforcement Fairness Act of 1996 (Public Law 104– 121), we want to assist small entities in understanding this proposed rule. If the rule would affect your small business, organization, or governmental jurisdiction, and you have questions concerning its provisions or options for compliance, please contact the person listed in the FOR FURTHER INFORMATION CONTACT section. The Coast Guard will not retaliate against small entities that question or complain about this proposed rule or any policy or action of the Coast Guard. C. Collection of Information This proposed rule would not call for a new collection of information under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501–3520). D. Federalism and Indian Tribal Governments A rule has implications for federalism under Executive Order 13132, Federalism, if it has a substantial direct effect on the States, on the relationship between the national government and E:\FR\FM\08MRP1.SGM 08MRP1

Agencies

[Federal Register Volume 84, Number 46 (Friday, March 8, 2019)]
[Proposed Rules]
[Pages 8488-8489]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-04203]


-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[REG-104352-18]
RIN 1545-BO53


Rules Regarding Certain Hybrid Arrangements; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Proposed rule; notice of hearing.

-----------------------------------------------------------------------

SUMMARY: This document provides a notice of public hearing on proposed 
regulations to implement sections 245A(e) and 267A of the Internal 
Revenue Code (Code) regarding hybrid dividends and certain amounts paid 
or accrued in hybrid transactions or with hybrid entities, and to 
provide rules under sections 1503(d) and 7701 of the Code to prevent 
the same deduction from being claimed under the tax laws of both the 
United States and a foreign country.

DATES: The public hearing is being held on Wednesday, March 20, 2019, 
at 10 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Friday, March 15, 2019.

ADDRESSES: The public hearing is being held in the IRS Auditorium, 
Internal Revenue Service Building, 1111 Constitution Avenue NW, 
Washington, DC 20224. Due to building security procedures, visitors 
must enter at the Constitution Avenue entrance. In addition, all 
visitors must present a valid photo identification to enter the 
building.
    Send Submissions to CC:PA:LPD:PR (REG-104352-18), Room 5205, 
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday to CC:PA:LPD:PR (REG-104352-18), Couriers 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-104352-18).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
contact Tracy Villecco at (202) 317-3800; concerning submissions of 
comments, the hearing and/or to be placed on the building access list 
to attend the hearing, Regina L. Johnson at (202) 317-6901 (not toll 
free numbers) or fdms.database@irscounsel.treas.gov.

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking (REG-104352-18) that was published in the 
Federal Register on Friday, December 28, 2018 (83 FR 67612).
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments at the hearing that submitted written 
comments by February 26, 2019, must submit an outline of the topics to 
be addressed and the amount of time to be devoted to each topic by 
Friday, March 15, 2019.
    A period of 10 minutes is allotted to each person for presenting 
oral comments. After the deadline for receiving outlines has passed, 
the IRS will prepare an agenda containing the schedule of speakers. 
Copies of the agenda will be made available, free of charge, at the 
hearing or by contacting the Publications and Regulations Branch at 
(202) 317-6901(not a toll-free number).
    Because of access restrictions, the IRS will not admit visitors 
beyond the immediate entrance area more than 30 minutes before the 
hearing starts. For

[[Page 8489]]

information about having your name placed on the building access list 
to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section 
of this document.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-04203 Filed 3-7-19; 8:45 am]
 BILLING CODE 4830-01-P