Recognition and Deferral of Section 987 Gain or Loss; Correction, 31194 [2019-13615]

Download as PDF 31194 § 232.301 Federal Register / Vol. 84, No. 126 / Monday, July 1, 2019 / Rules and Regulations EDGAR Filer Manual. Filers must prepare electronic filings in the manner prescribed by the EDGAR Filer Manual, promulgated by the Commission, which sets forth the technical formatting requirements for electronic submissions. The requirements for becoming an EDGAR Filer and updating company data are set forth in the updated EDGAR Filer Manual, Volume I: ‘‘General Information,’’ Version 33 (June 2019). The requirements for filing on EDGAR are set forth in the updated EDGAR Filer Manual, Volume II: ‘‘EDGAR Filing,’’ Version 51 (June 2019). All of these provisions have been incorporated by reference into the Code of Federal Regulations, which action was approved by the Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You must comply with these requirements in order for documents to be timely received and accepted. The EDGAR Filer Manual is available for website viewing and printing; the address for the Filer Manual is https://www.sec.gov/info/ edgar/edmanuals.htm. You can obtain paper copies of the EDGAR Filer Manual at the following address: Public Reference Room, U.S. Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549, on official business days between the hours of 10:00 a.m. and 3:00 p.m. You can also inspect the document at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202–741–6030, or go to: https:// www.archives.gov/federal-register/cfr/ ibr-locations.html. By the Commission. Dated: June 7, 2019 Jill M. Peterson, Assistant Secretary. 9857) that were published in the Federal Register on Monday, May 13, 2019. The final regulations are relating to combinations and separations of qualified business units (QBUs) subject to section 987 and the recognition and deferral of foreign currency gain or loss with respect to a QBU subject to section 987 in connection with certain QBU terminations and certain other transactions involving partnerships. DATES: This correction is effective on July 1, 2019. FOR FURTHER INFORMATION CONTACT: Steven D. Jensen at (202) 317–6938 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations (TD 9857) that are the subject of this correction are issued under section 987 of the Internal Revenue Code. Need for Correction As published May 13, 2019 (84 FR 20790) the final regulations (TD 9857) contain errors that need to be corrected. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Correction of Publication Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: ■ Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.987–0 is amended by revising the entries of the table of contents for § 1.987–12(b) and (j) to read as follows: ■ [FR Doc. 2019–13922 Filed 6–28–19; 8:45 am] § 1.987–0 BILLING CODE 8011–01–P * DEPARTMENT OF THE TREASURY § 1.987–12 loss. Internal Revenue Service * 26 CFR Part 1 [TD 9857] RIN 1545–BL11 khammond on DSKBBV9HB2PROD with RULES * Recognition and Deferral of Section 987 Gain or Loss; Correction Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. AGENCY: This document contains corrections to final regulations (TD SUMMARY: VerDate Sep<11>2014 15:54 Jun 28, 2019 Jkt 247001 Table of contents. * * Deferral of section 987 gain or § 1.987–2 Attribution of items to eligible QBUs; definition of a transfer and related rules. PO 00000 * * Frm 00024 * Fmt 4700 * Sfmt 4700 § 1.987–4 Determination of net unrecognized section 987 gain or loss of a section 987 QBU. * * * * * (f) * * * (2) * * * For purposes of determining the owner functional currency net value of the separated QBUs on the last day of the taxable year preceding the taxable year of separation under paragraphs (d)(1)(B) and (e) of this section, the balance sheets of the separated QBUs on that day will be deemed to reflect the assets and liabilities reflected on the balance sheet of the separating QBU on that day, apportioned between the separated QBUs in a reasonable manner that takes into account the assets and liabilities reflected on the balance sheets of the separated QBUs immediately after the separation. * * * * * * * * Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. 2019–13615 Filed 6–28–19; 8:45 am] BILLING CODE 4830–01–P OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE * * * * * (b) Gain and loss recognition in connection with a deferral event. * * * * * (j) Applicability date. * * * * * ■ Par. 3. Section 1.987–2 is amended by revising the fifth sentence of paragraph (c)(9)(iii) and revising paragraph (e)(1) to read as follows: * (c) * * * (9) * * * (iii) * * * A separation may also result when a section 987 QBU that is subject to a grouping election under § 1.987–1(b)(2)(ii) changes its functional currency. * * * * * * * * (e) * * * (1) In general. Except as set forth in paragraph (e)(2) of this section, this section is applicable as specified in § 1.987–11. * * * * * ■ Par. 4. Section 1.987–4 is amended by revising the third sentence of paragraph (f)(2) to read as follows: 32 CFR Part 1701 Privacy Act of 1974: System of Records Office of the Director of National Intelligence. ACTION: Final rule. AGENCY: The Office of the Director of National Intelligence (ODNI) exempts a new system of records (Continuous Evaluation System) from the requirements of the Privacy Act to the extent that information in the system is subject to the Privacy Act’s exemption provisions. The ODNI also adds a new SUMMARY: E:\FR\FM\01JYR1.SGM 01JYR1

Agencies

[Federal Register Volume 84, Number 126 (Monday, July 1, 2019)]
[Rules and Regulations]
[Page 31194]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-13615]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9857]
RIN 1545-BL11


Recognition and Deferral of Section 987 Gain or Loss; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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

SUMMARY: This document contains corrections to final regulations (TD 
9857) that were published in the Federal Register on Monday, May 13, 
2019. The final regulations are relating to combinations and 
separations of qualified business units (QBUs) subject to section 987 
and the recognition and deferral of foreign currency gain or loss with 
respect to a QBU subject to section 987 in connection with certain QBU 
terminations and certain other transactions involving partnerships.

DATES: This correction is effective on July 1, 2019.

FOR FURTHER INFORMATION CONTACT: Steven D. Jensen at (202) 317-6938 
(not a toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final regulations (TD 9857) that are the subject of this 
correction are issued under section 987 of the Internal Revenue Code.

Need for Correction

    As published May 13, 2019 (84 FR 20790) the final regulations (TD 
9857) contain errors that need to be corrected.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Correction of Publication

    Accordingly, 26 CFR part 1 is corrected by making the following 
correcting amendments:

PART 1--INCOME TAXES

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

    Authority:  26 U.S.C. 7805 * * *


0
Par. 2. Section 1.987-0 is amended by revising the entries of the table 
of contents for Sec.  1.987-12(b) and (j) to read as follows:


Sec.  1.987-0  Table of contents.

* * * * *


Sec.  1.987-12  Deferral of section 987 gain or loss.

* * * * *
    (b) Gain and loss recognition in connection with a deferral event.
* * * * *
    (j) Applicability date.
* * * * *

0
Par. 3. Section 1.987-2 is amended by revising the fifth sentence of 
paragraph (c)(9)(iii) and revising paragraph (e)(1) to read as follows:


Sec.  1.987-2   Attribution of items to eligible QBUs; definition of a 
transfer and related rules.

* * * * *
    (c) * * *
    (9) * * *
    (iii) * * * A separation may also result when a section 987 QBU 
that is subject to a grouping election under Sec.  1.987-1(b)(2)(ii) 
changes its functional currency. * * *
* * * * *
    (e) * * *
    (1) In general. Except as set forth in paragraph (e)(2) of this 
section, this section is applicable as specified in Sec.  1.987-11.
* * * * *

0
Par. 4. Section 1.987-4 is amended by revising the third sentence of 
paragraph (f)(2) to read as follows:


Sec.  1.987-4  Determination of net unrecognized section 987 gain or 
loss of a section 987 QBU.

* * * * *
    (f) * * *
    (2) * * * For purposes of determining the owner functional currency 
net value of the separated QBUs on the last day of the taxable year 
preceding the taxable year of separation under paragraphs (d)(1)(B) and 
(e) of this section, the balance sheets of the separated QBUs on that 
day will be deemed to reflect the assets and liabilities reflected on 
the balance sheet of the separating QBU on that day, apportioned 
between the separated QBUs in a reasonable manner that takes into 
account the assets and liabilities reflected on the balance sheets of 
the separated QBUs immediately after the separation. * * *
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-13615 Filed 6-28-19; 8:45 am]
 BILLING CODE 4830-01-P