Recurring Safety Zone; Chester Fireworks, Chester, WV, 23719-23720 [2019-10763]
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Federal Register / Vol. 84, No. 100 / Thursday, May 23, 2019 / Rules and Regulations
United States property held by FC ($120x)
over the earnings and profits described in
section 959(c)(1)(A) with respect to USP
($100x), and its pro rata share of FC’s
applicable earnings ($100x). Under paragraph
(a)(2)(i) of this section, USP’s section 956
amount with respect to FC is its aggregate
tentative section 956 amount with respect to
FC reduced by the deduction under section
245A that USP would be allowed if USP
received an amount equal to its aggregate
tentative section 956 amount as a distribution
with respect to the FC stock. USP would be
allowed a $20x deduction under section
245A with respect to the foreign-source
portion of the $20x hypothetical distribution,
which, under paragraph (a)(2)(ii)(C) of this
section, is treated as attributable to the
earnings and profits of FC described in
section 959(c)(3) despite the fact that FC has
$100x of earnings and profits described in
section 959(c)(1)(A) that would otherwise be
distributed before earnings and profits
described in section 959(c)(3). Accordingly,
USP’s section 956 amount with respect to FC
is $0, its aggregate tentative section 956
amount ($20x) with respect to FC reduced by
the amount of the deduction that USP would
have been allowed under section 245A with
respect to the hypothetical distribution after
applying the rule in paragraph (a)(2)(ii)(C) of
this section ($20x).
(iv) Example 4—(A) Facts. The facts are the
same as in paragraph (a)(3)(i)(A) of this
section (the facts in Example 1), except that
USP is a domestic partnership in which
USC1 and USC2, each a domestic
corporation, and USI, a United States citizen,
have owned 50%, 30%, and 20%,
respectively, of the capital and profits
interests for five years.
(B) Analysis. As in paragraph (a)(3)(i)(B) of
this section (the analysis in Example 1),
USP’s aggregate tentative section 956 amount
with respect to FC is $100x. Under paragraph
(a)(2)(i) of this section, USP’s section 956
amount with respect to FC is its aggregate
tentative section 956 amount with respect to
FC reduced by the aggregate amount of
deductions under section 245A that USC1,
USC2, and USI would be allowed if USP
received an amount equal to its aggregate
tentative section 956 amount as a distribution
with respect to the FC stock. Assuming that,
under section 245A, USC1 and USC2 would
be allowed a $45x deduction and a $27x
deduction, respectively, with respect to the
foreign-source portion of their $50x and $30x
distributive shares of the $100x hypothetical
distribution (that is, an amount of the
dividend that bears the same ratio to the
dividend as the $90x of undistributed foreign
earnings bears to the $100x of undistributed
earnings), USP’s section 956 amount with
respect to FC is $28x, its aggregate tentative
section 956 amount ($100x) with respect to
FC reduced by the aggregate amount of the
deductions that its partners would have been
allowed under section 245A with respect to
the hypothetical distribution ($72x ($45x +
$27x)). Under paragraph (a)(2)(iii) of this
section, the portion of its $28x inclusion
under section 951(a)(1)(B) with respect to FC
that is allocated to USC1 is $5x ($28x x
(($50x¥$45x)/($50x¥$45x + $30x¥$27x +
$20x))); the portion that is allocated to USC2
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is $3x ($28x x (($30x¥$27x) / ($50x¥$45x
+ $30x¥$27x + $20x))); and the portion that
is allocated to USI is $20x ($28x x ($20x /
($50x¥$45x + $30x¥$27x + $20x))).
(v) Example 5—(A) Facts. (1) USP, a
domestic corporation, owns all of the single
class of stock of FC1, a foreign corporation,
and has held such stock for five years. FC1
has held 70% of the single class of stock of
FC2, a foreign corporation, for three years.
The other 30% of the FC2 stock has been
held since FC2’s formation by a foreign
individual unrelated to USP or FC1. Any
dividend from FC2 or FC1 to FC1 or USP,
respectively, would not constitute a hybrid
dividend for purposes of section 245A(e).
FC2 has a calendar taxable year. On
December 1, Year 1, FC1 acquires the
remaining 30% of the stock of FC2 for cash.
On June 30, Year 2, FC1 sells to a third party
the 30% of FC2 stock acquired in Year 1 at
no gain. FC2 made no distributions during
Year 1.
(2) The functional currency of FC1 and FC2
is the U.S. dollar. For Year 1, FC2 has $120x
of undistributed earnings as defined in
section 245A(c)(2), all of which constitute
undistributed foreign earnings. None of the
earnings and profits of FC2 are described in
section 959(c)(1) or (2) or are earnings and
profits attributable to income excluded from
subpart F income under section 952(b). FC2’s
applicable earnings (as defined in section
956(b)(1)) for Year 1 are $120x. FC2 has held
an obligation of USP with an adjusted basis
of $100x on every day of Year 1 that was
acquired while USP owned all of the stock
of FC1 and FC1 held 70% of the single class
of stock of FC2.
(B) Analysis. Because USP indirectly owns
(within the meaning of section 958(a)) all of
the stock of FC2 at the end of Year 1, USP’s
aggregate tentative section 956 amount with
respect to FC2 for Year 1 is $100x, the lesser
of USP’s pro rata share of the average
amounts of United States property held by
FC2 ($100x) and its pro rata share of FC2’s
applicable earnings ($120x). Under paragraph
(a)(2)(i) of this section, USP’s section 956
amount with respect to FC2 for Year 1 is its
aggregate tentative section 956 amount with
respect to FC2 reduced by the deduction
under section 245A that USP would be
allowed if USP received an amount equal to
its aggregate tentative section 956 amount as
a distribution with respect to the FC2 stock
that USP owns indirectly within the meaning
of section 958(a)(2). For purposes of
determining the consequences of this
hypothetical distribution, under paragraph
(a)(2)(ii)(A)(1) of this section, USP is treated
as owning the FC2 stock directly. In addition,
under paragraph (a)(2)(ii)(A)(4) of this
section, the holding period requirement of
section 246(c) is applied by reference to the
period during which USP owned (within the
meaning of section 958(a)) the stock of FC2.
Therefore, with respect to the hypothetical
distribution from FC2 to USP, USP would
satisfy the holding period requirement under
section 246(c) with respect to the 70% of the
FC2 stock that USP indirectly owned for
three years through FC1, but not with respect
to the 30% of the FC2 stock that USP
indirectly owned through FC1 for a period of
less than 365 days. Accordingly, USP’s
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23719
section 956 amount with respect to FC2 for
Year 1 is $30x, its aggregate tentative section
956 amount ($100x) reduced by the amount
of the deduction that USP would have been
allowed under section 245A with respect to
the hypothetical distribution ($70x).
*
*
*
*
*
(g) Applicability dates.* * *
(4) Paragraphs (a)(2) and (3) of this
section apply to taxable years of
controlled foreign corporations
beginning on or after July 22, 2019, and
to taxable years of a United States
shareholder in which or with which
such taxable years of the controlled
foreign corporations end.
Notwithstanding the preceding
sentence, a United States shareholder
may apply paragraphs (a)(2) and (3) of
this section to taxable years of
controlled foreign corporations
beginning after December 31, 2017, and
to taxable years of the United States
shareholder in which or with which
such taxable years of the controlled
foreign corporations end, provided that
the United States shareholder and
United States persons that are related
(within the meaning of section 267 or
707) to the United States shareholder
consistently apply those paragraphs
with respect to all controlled foreign
corporations in which they are United
States shareholders for taxable years of
the controlled foreign corporations
beginning after December 31, 2017.
(5) Paragraph (e)(6) of this section
applies to property acquired in
exchanges occurring on or after June 24,
2011.
Kirsten Wielobob,
Deputy Commissioner for Services and
Enforcement.
Approved: May 9, 2019.
David J. Kautter,
Assistant Secretary of the Treasury (Tax
Policy).
[FR Doc. 2019–10749 Filed 5–22–19; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 165
[Docket No. USCG–2019–0240]
Recurring Safety Zone; Chester
Fireworks, Chester, WV
Coast Guard, DHS.
Notice of enforcement of
regulation.
AGENCY:
ACTION:
The Coast Guard will enforce
the temporary safety zone for the
SUMMARY:
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23720
Federal Register / Vol. 84, No. 100 / Thursday, May 23, 2019 / Rules and Regulations
Chester Volunteer Fire Department
Fireworks, to provide for the safety of
persons, vessels, and the marine
environment on the navigable waters of
the Ohio River during this event. Our
regulation for marine events within the
Eighth Coast Guard District identifies
the regulated area for this event in
Chester, WV. During the enforcement
period, entry into this zone is prohibited
unless authorized by the Captain of the
Port Marine Safety Unit Pittsburgh or a
designated representative.
Dated: May 13, 2019.
A.W. Demo,
Commander, U.S. Coast Guard, Captain of
the Port Marine Safety Unit Pittsburgh.
The regulations in 33 CFR
165.801, Table 1, Line 38, will be
enforced from 9:30 p.m. through 11 p.m.
on July 4, 2019.
[Docket No. USCG–2019–0239]
If
you have questions about this notice of
enforcement, call or email Petty Officer
Jennifer Haggins, Marine Safety Unit
Pittsburgh, U.S. Coast Guard; telephone
412–221–0807, email
Jennifer.L.Haggins@uscg.mil.
AGENCY:
DATES:
FOR FURTHER INFORMATION CONTACT:
The Coast
Guard will enforce a temporary safety
zone for the Chester Volunteer Fire
Department Fireworks, in 33 CFR
165.801, Table 1, Line 38 from 9:30 p.m.
through 11:00 p.m. on July 4, 2019. This
action is being taken to provide for the
safety of persons, vessels, and the
marine environment on the navigable
waters of the Ohio River during this
event. Our regulation for marine events
within the Eighth Coast Guard District,
§ 165.801, specifies the location of the
safety zone for the Chester Volunteer
Fire Department Fireworks, which
covers a one mile stretch of the Ohio
River. Entry into the safety zone is
prohibited unless authorized by the
Captain of the Port Marine Safety Unit
Pittsburgh (COTP) or a designated
representative. Persons or vessels
desiring to enter into or pass through
the area must request permission from
the COTP or a designated
representative. They can be reached on
VHF FM channel 16. If permission is
granted, all persons and vessel shall
comply with the instructions of the
COTP or designated representative.
In addition to this notice of
enforcement in the Federal Register, the
COTP or a designated representative
will inform the public through
Broadcast Notices to Mariners (BNMs),
Local Notices to Mariners (LNMs),
Marine Safety Information Bulletins
(MSIBs), and/or through other means of
public notice as appropriate at least 24
hours in advance of enforcement.
khammond on DSKBBV9HB2PROD with RULES
SUPPLEMENTARY INFORMATION:
VerDate Sep<11>2014
16:07 May 22, 2019
Jkt 247001
[FR Doc. 2019–10763 Filed 5–22–19; 8:45 am]
BILLING CODE 9110–04–P
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 165
Recurring Safety Zone; PUSH Beaver
County, Beaver, PA
Coast Guard, DHS.
Notice of enforcement of
regulation.
ACTION:
The Coast Guard will enforce
the annual safety zone for the PUSH
Beaver County Fireworks, to provide for
the safety of persons, vessels, and the
marine environment on the navigable
waters of Ohio River during this event.
Our regulation for marine events within
the Eighth Coast Guard District
identifies the regulated area for this
event in Beaver, PA. During the
enforcement period, entry into this zone
is prohibited unless authorized by the
Captain of the Port Marine Safety Unit
Pittsburgh or a designated
representative.
SUMMARY:
The regulations in 33 CFR
165.801, Table 1, Line 20 will be
enforced from 8 p.m. through 10:30 p.m.
on June 22, 2019, unless the firework
display is postponed because of adverse
weather, in which case, this rule will be
enforced on June 23, 2019.
FOR FURTHER INFORMATION CONTACT: If
you have questions about this notice of
enforcement, call or email Petty Officer
Jennifer Haggins, Marine Safety Unit
Pittsburgh, U.S. Coast Guard; telephone
412–221–0807, email
Jennifer.L.Haggins@uscg.mil.
SUPPLEMENTARY INFORMATION: The Coast
Guard will enforce the annual safety
zone on the Ohio River for the PUSH
Beaver County, in 33 CFR 165.801,
Table 1, Line 20 from 8:00 p.m. through
10:30 p.m. on June 22, 2019, unless the
firework display is postponed because
of adverse weather, in which case, this
rule will be enforced on June 23, 2019.
This action is being taken to provide for
the safety of persons, vessels, and the
marine environment on the navigable
waters of the Ohio River during this
event. Our regulation for marine events
within the Eighth Coast Guard District,
§ 165.801, Table 1, Line 20, specifies the
DATES:
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Fmt 4700
Sfmt 4700
location of the safety zone for the PUSH
Beaver County, which covers a one half
mile stretch of the Ohio River. Entry
into the safety zone is prohibited unless
authorized by the Captain of the Port
Marine Safety Unit Pittsburgh (COTP) or
a designated representative. Persons or
vessels desiring to enter into or pass
through the area must request
permission from the COTP or a
designated representative. They can be
reached on VHF FM channel 16. If
permission is granted, all persons and
vessel shall comply with the
instructions of the COTP or designated
representative.
In addition to this notice of
enforcement in the Federal Register, the
COTP or a designated representative
will inform the public through
Broadcast Notices to Mariners (BNMs),
Local Notices to Mariners (LNMs),
Marine Safety Information Bulletins
(MSIBs), and/or through other means of
public notice as appropriate at least 24
hours in advance of enforcement.
Dated: May 20, 2019.
A.W. Demo,
Commander, U.S. Coast Guard, Captain of
the Port Marine Safety Unit Pittsburgh.
[FR Doc. 2019–10771 Filed 5–22–19; 8:45 am]
BILLING CODE 9110–04–P
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 165
[Docket No. USCG–2019–0229]
Recurring Safety Zone; Wheeling
Annual Dragon Boat Race, Wheeling,
WV
Coast Guard, DHS.
Notice of enforcement of
regulation.
AGENCY:
ACTION:
The Coast Guard will enforce
the safety zone for the Wheeling Annual
Dragon Boat Race to provide for the
safety of persons, vessels, and the
marine environment on the navigable
waters of the Ohio River during this
event. Our regulation for marine events
within the Eighth Coast Guard District
identifies the regulated area for this
event in Wheeling, WV. During the
enforcement periods, entry into this
zone is prohibited unless authorized by
the Captain of the Port Marine Safety
Unit Pittsburgh or a designated
representative.
SUMMARY:
The regulations in 33 CFR
165.801, Table 1, Line 70, will be
DATES:
E:\FR\FM\23MYR1.SGM
23MYR1
]]>Agencies
[Federal Register Volume 84, Number 100 (Thursday, May 23, 2019)]
[Rules and Regulations]
[Pages 23719-23720]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-10763]
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DEPARTMENT OF HOMELAND SECURITY
Coast Guard
33 CFR Part 165
[Docket No. USCG-2019-0240]
Recurring Safety Zone; Chester Fireworks, Chester, WV
AGENCY: Coast Guard, DHS.
ACTION: Notice of enforcement of regulation.
-----------------------------------------------------------------------
SUMMARY: The Coast Guard will enforce the temporary safety zone for the
[[Page 23720]]
Chester Volunteer Fire Department Fireworks, to provide for the safety
of persons, vessels, and the marine environment on the navigable waters
of the Ohio River during this event. Our regulation for marine events
within the Eighth Coast Guard District identifies the regulated area
for this event in Chester, WV. During the enforcement period, entry
into this zone is prohibited unless authorized by the Captain of the
Port Marine Safety Unit Pittsburgh or a designated representative.
DATES: The regulations in 33 CFR 165.801, Table 1, Line 38, will be
enforced from 9:30 p.m. through 11 p.m. on July 4, 2019.
FOR FURTHER INFORMATION CONTACT: If you have questions about this
notice of enforcement, call or email Petty Officer Jennifer Haggins,
Marine Safety Unit Pittsburgh, U.S. Coast Guard; telephone 412-221-
0807, email [email protected].
SUPPLEMENTARY INFORMATION: The Coast Guard will enforce a temporary
safety zone for the Chester Volunteer Fire Department Fireworks, in 33
CFR 165.801, Table 1, Line 38 from 9:30 p.m. through 11:00 p.m. on July
4, 2019. This action is being taken to provide for the safety of
persons, vessels, and the marine environment on the navigable waters of
the Ohio River during this event. Our regulation for marine events
within the Eighth Coast Guard District, Sec. 165.801, specifies the
location of the safety zone for the Chester Volunteer Fire Department
Fireworks, which covers a one mile stretch of the Ohio River. Entry
into the safety zone is prohibited unless authorized by the Captain of
the Port Marine Safety Unit Pittsburgh (COTP) or a designated
representative. Persons or vessels desiring to enter into or pass
through the area must request permission from the COTP or a designated
representative. They can be reached on VHF FM channel 16. If permission
is granted, all persons and vessel shall comply with the instructions
of the COTP or designated representative.
In addition to this notice of enforcement in the Federal Register,
the COTP or a designated representative will inform the public through
Broadcast Notices to Mariners (BNMs), Local Notices to Mariners (LNMs),
Marine Safety Information Bulletins (MSIBs), and/or through other means
of public notice as appropriate at least 24 hours in advance of
enforcement.
Dated: May 13, 2019.
A.W. Demo,
Commander, U.S. Coast Guard, Captain of the Port Marine Safety Unit
Pittsburgh.
[FR Doc. 2019-10763 Filed 5-22-19; 8:45 am]
BILLING CODE 9110-04-P
