Recognition and Deferral of Section 987 Gain or Loss; Correction, 31194 [2019-13615]
Download as PDF
<![CDATA[
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]
=======================================================================
-----------------------------------------------------------------------
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
