Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income; Hearing, 25208-25209 [2019-11388]
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Federal Register / Vol. 84, No. 105 / Friday, May 31, 2019 / Proposed Rules
will consider comments filed after the
comment period has closed if it is
possible to do so without incurring
expense or delay. The agency may
change this proposal in light of the
comments it receives.
B. Availability of Rulemaking
Documents
An electronic copy of rulemaking
documents may be obtained from the
internet by—
1. Searching the Federal eRulemaking
Portal (https://www.regulations.gov);
2. Visiting the FAA’s Regulations and
Policies web page at https://
www.faa.gov/regulations_policies or
3. Accessing the Government Printing
Office’s web page at https://
www.gpo.gov/fdsys/.
Copies may also be obtained by
sending a request to the Federal
Aviation Administration, Office of
Rulemaking, 800 Independence Avenue
SW, Washington, DC 20591, or by
calling (202) 267–9680. Commenters
must identify the docket or notice
number of this rulemaking.
All documents the FAA considered in
developing this proposed rule,
including economic analyses and
technical reports, may be accessed from
the internet through the Federal
eRulemaking Portal referenced in item
(1) above.
Background
On March 26, 2019, the FAA posted
a draft copy of the NPRM entitled
‘‘Streamlined Launch and Reentry
Licensing Requirements’’ on its website
for public preview. On April 15, 2019,
this rule, containing minimal changes,
was published as Notice No. 19–01 in
the Federal Register (84 FR 15296).
Commenters were instructed to provide
comments on or before June 14, 2019.
Since publication, fifty-six
commenters 1 have requested an
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1 The
commenters are Aerospace Industries
Association (AIA), Analytical Graphics Inc. (AGI),
Aircraft Owners and Pilots Association (AOPA),
Airlines for America, Airports Council
International—North America (ACI), Air Line Pilots
Association (ALPA), American Association of
Airline Executives (AAAE), Arete STEM
Foundation, Arizona State University, Atomos
Space, Axiom, Blue Origins, Colorado Air and
Space Port, Exos Aerospace, Generation Orbit,
Houston Space Port, Heinlein Prize Trust, Johns
Hopkins University, InterFlight Global Corporation,
Leo Aerospace, Maxar Technologies, Midland
International Air & Space Port, Misty Harbor HOA,
MLA Space, Mojave Air & Space Port, Momentus,
Moon Express, National Air Traffic Controllers
Association (NATCA), New Mexico Spaceport
Authority, Purdue School of Aeronautics and
Astronautics, Quest for Stars, Regional Airline
Association (RAA), Sierra Nevada Corporation,
Spaceport Strategies LLC, SpaceX, Space Angels,
Space Florida, Spaceport Camden, SpinLaunch,
Southwest Research Institute, TeamHealth
VerDate Sep<11>2014
16:12 May 30, 2019
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extension of the comment period to a
total of 120 days, or until August 13,
2019, citing the proposed rule’s breadth,
significant impact, length, and
complexity. The commenters stated a
longer time frame is necessary in order
to fully review the proposed rule and
develop comments and
recommendations.
The FAA agrees with the petitioners’
request for an extension of the comment
period. It recognizes the content of the
proposed rule is significant and
complex, and that an extension would
help commenters craft complete and
thoughtful responses. Because the rule
was posted on the FAA’s website 20
days prior to its publication in the
Federal Register, the FAA is extending
the comment period an additional 45
days. With this extension, the comment
period will now close on July 30, 2019.
This will provide the public with a total
of 125 days to conduct its review.
The FAA does not anticipate any
further extension of the comment period
for this rulemaking.
Extension of Comment Period
In accordance with § 11.47(c) of Title
14, Code of Federal Regulations, the
FAA has reviewed the petitions for
extension of the comment period for
this notice. The petitioners have shown
a substantive interest in the proposed
policy and good cause for the extension
of the comment period. The FAA has
determined that an extension of the
comment period for an additional 45
days to July 30, 2019, is consistent with
the public interest, and that good cause
exists for taking this action.
Accordingly, the comment period for
Notice No. 19–01 is extended until July
30, 2019.
Issued under authority provided by 49
U.S.C. 106(f), 44701(a), and 44703 in
Washington, DC, on May 24, 2019.
Lirio Liu,
Executive Director, Office of Rulemaking.
[FR Doc. 2019–11286 Filed 5–30–19; 8:45 am]
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Healthcare Staffing, Techshot, TIP Technologies,
Vector Launch, Virgin Galactic, Virgin Orbit, World
View, Xplore Inc., and various members of the
public.
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 163
[REG–104464–18]
RIN 1545–BO55
Deduction for Foreign-Derived
Intangible Income and Global
Intangible Low-Taxed Income; 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 provide guidance to
determine the amount of the deduction
for foreign-derived intangible income
and global intangible low-taxed income.
DATES: The public hearing is being held
on Wednesday, July 10, 2019, at 10:00
a.m. The IRS must receive speakers’
outlines of the topics to be discussed at
the public hearing by Monday, July 1,
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–104464–18), 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–104464–18),
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–104464–
18).
FOR FURTHER INFORMATION CONTACT:
Concerning proposed §§ 1.250(a)–1
through 1.250(b)–6, 1.962–1, 1.6038–2,
1.6038–3, and 1.6038A–2, Kenneth
Jeruchim at (202) 317–6939; concerning
proposed §§ 1.1502–12, 1.1502–13 and
1.1502–50, Michelle A. Monroy at (202)
317–5363 or Austin Diamond-Jones at
(202) 317–6847; concerning submissions
of comments, the hearing and/or to be
placed on the building access list to
attend the hearing, Regina Johnson at
(202) 317–6901 (not toll-free numbers),
fdms.database@irscounsel.treas.gov.
SUPPLEMENTARY INFORMATION: The
subject of the public hearing is the
SUMMARY:
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Federal Register / Vol. 84, No. 105 / Friday, May 31, 2019 / Proposed Rules
notice of proposed rulemaking (REG–
104464–18) that was published in the
Federal Register on Wednesday, March
6, 2019 (84 FR 8188).
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
May 6, 2019, must submit an outline of
the topics to be addressed and the
amount of time to be devoted to each
topic by Monday, July 1, 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) fdms.database@
irscounsel.treas.gov.
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. 2019–11388 Filed 5–30–19; 8:45 am]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 31
[REG–132240–15]
RIN 1545–BN52
Withholding on Certain Distributions
Under Section 3405(a) and (b)
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking.
AGENCY:
This document contains a
proposed regulation regarding
withholding on certain periodic and
nonperiodic distributions under section
3405, other than eligible rollover
distributions. This regulation would
affect payors and payees of these
distributions.
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SUMMARY:
Written or electronic comments
and must be received by August 29,
2019.
DATES:
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16:12 May 30, 2019
Jkt 247001
Send submissions to
CC:PA:LPD:PR (REG–132240–15), 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–132240–
15), 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 (indicate IRS REG–
132240–15).
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulation,
Jeremy D. Lamb at (202) 317–6799;
concerning submissions of comments,
Regina Johnson at (202) 317–6901 (not
toll-free numbers).
SUPPLEMENTARY INFORMATION:
ADDRESSES:
Background
Section 3405(a)(1) requires the payor
of any periodic payment to withhold
income tax from the payment. Under
section 3405(a)(2), an individual
generally may elect not to have section
3405(a)(1) apply with respect to
periodic payments made to the
individual. Section 3405(b)(1) requires
the payor of any nonperiodic
distribution to withhold income tax
from the distribution. Under section
3405(b)(2), an individual generally may
elect not to have section 3405(b)(1)
apply with respect to any nonperiodic
distribution.
Section 3405(e)(2) defines a periodic
payment as a designated distribution
that is an annuity or similar periodic
payment. Section 3405(e)(3) defines a
nonperiodic distribution as any
designated distribution that is not a
periodic payment. A designated
distribution generally is defined in
section 3405(e)(1) as any distribution or
payment from or under an employer
deferred compensation plan, an
individual retirement plan (as defined
in section 7701(a)(37)), or a commercial
annuity. For this purpose, an employer
deferred compensation plan is defined
in section 3405(e)(5) as any pension,
annuity, profit sharing, or stock bonus
plan or other plan deferring the receipt
of compensation, and a commercial
annuity is defined in section 3405(e)(6)
as an annuity, endowment, or life
insurance contract issued by an
insurance company licensed to do
business under the laws of any State.
Section 3405(e)(1)(B) identifies
certain amounts or payments that are
not a ‘‘designated distribution’’ for
purposes of section 3405 withholding.
Under section 3405(e)(1)(B)(iii), any
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25209
amount that is subject to withholding
under subchapter A of chapter 3
(relating to withholding of tax on
nonresident aliens and foreign
corporations) by the person paying such
amount or which would be so subject
but for a tax treaty is not a designated
distribution.
Section 3405(e)(13)(A) provides
generally that, in the case of any
periodic payment or nonperiodic
distribution that is ‘‘to be delivered
outside of the United States and any
possession of the United States,’’ no
election may be made under section
3405(a)(2) or (b)(2) with respect to such
payment, with the result that
withholding may not be waived. Section
3405(e)(13)(B) provides that section
3405(e)(13)(A) does not apply if the
recipient certifies to the payor, in such
manner as the Secretary of the Treasury
may prescribe, that the recipient is not
(i) a United States citizen or a resident
alien of the United States, or (ii) an
individual to whom section 877 applies.
Section 877(h) provides that section 877
applies to certain nonresident alien
individuals whose expatriation date, as
defined in section 877A(g)(3), is before
June 17, 2008.
Notice 87–7 (1987–1 C.B. 420), see
§ 601.601(d)(2)(ii)(b), provides guidance
under section 3405(e)(13)(A) to payors
of designated distributions with respect
to their duty to withhold income tax
from such distributions. The notice
addresses designated distributions to
the following categories of payees: (1)
Payees who have provided the payors
with a residence address outside of the
United States; 1 (2) payees who have
provided the payors with a residence
address within the United States; and
(3) payees who have not provided the
payors with a residence address.
Notice 87–7 specifies that, if a payee
has provided the payor with a residence
address outside of the United States, the
payor is required to withhold income
tax from designated distributions to the
payee. If a payee has provided the payor
with a residence address within the
United States, the payor is required to
withhold income tax from these
distributions to the payee unless the
payee has elected no withholding in
accordance with the applicable
provisions of section 3405. If a payee
has not provided the payor with a
residence address, the payor is required
to withhold income tax from designated
distributions; included within this
category is a payee who has provided
the payor with an address for the
1 For purposes of this preamble, references to the
‘‘United States’’ include any possession of the
United States.
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Agencies
[Federal Register Volume 84, Number 105 (Friday, May 31, 2019)]
[Proposed Rules]
[Pages 25208-25209]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-11388]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 163
[REG-104464-18]
RIN 1545-BO55
Deduction for Foreign-Derived Intangible Income and Global
Intangible Low-Taxed Income; 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 provide guidance to determine the amount of the
deduction for foreign-derived intangible income and global intangible
low-taxed income.
DATES: The public hearing is being held on Wednesday, July 10, 2019, at
10:00 a.m. The IRS must receive speakers' outlines of the topics to be
discussed at the public hearing by Monday, July 1, 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-104464-18), 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-104464-18), 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-104464-18).
FOR FURTHER INFORMATION CONTACT: Concerning proposed Sec. Sec.
1.250(a)-1 through 1.250(b)-6, 1.962-1, 1.6038-2, 1.6038-3, and
1.6038A-2, Kenneth Jeruchim at (202) 317-6939; concerning proposed
Sec. Sec. 1.1502-12, 1.1502-13 and 1.1502-50, Michelle A. Monroy at
(202) 317-5363 or Austin Diamond-Jones at (202) 317-6847; concerning
submissions of comments, the hearing and/or to be placed on the
building access list to attend the hearing, Regina Johnson at (202)
317-6901 (not toll-free numbers), [email protected].
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
[[Page 25209]]
notice of proposed rulemaking (REG-104464-18) that was published in the
Federal Register on Wednesday, March 6, 2019 (84 FR 8188).
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 May 6, 2019, must submit an outline of the topics to be
addressed and the amount of time to be devoted to each topic by Monday,
July 1, 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)
[email protected].
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. 2019-11388 Filed 5-30-19; 8:45 am]
BILLING CODE 4830-01-P