Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correction, 38866-38867 [2019-16631]
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38866
Federal Register / Vol. 84, No. 153 / Thursday, August 8, 2019 / Rules and Regulations
Paragraph 6005 Class E Airspace Areas
Extending Upward From 700 Feet or More
Above the Surface of the Earth.
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ACE IA E5
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Correction of Publication
Accordingly, 26 CFR part 1 is
corrected by making the following
correcting amendments:
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Sioux Center, IA [Removed]
Issued in Fort Worth, Texas, on July 31,
2019.
John Witucki,
Acting Manager, Operations Support Group,
ATO Central Service Center.
[FR Doc. 2019–16800 Filed 8–7–19; 8:45 am]
DEPARTMENT OF THE TREASURY
26 CFR Part 1
RIN 1545–BO64
Limitation on Deduction for Dividends
Received From Certain Foreign
Corporations and Amounts Eligible for
Section 954 Look-Through Exception;
Correcting Amendment
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
AGENCY:
This document contains
corrections to Treasury Decision 9865,
which was published in the Federal
Register for Tuesday, June 18, 2019.
Treasury Decision 9865 contained
temporary regulations under section
245A of the Internal Revenue Code (the
‘‘Code) that limit the dividends received
deduction available for certain
dividends received from current or
former controlled foreign corporations.
DATES: Effective date. These corrections
are effective on August 8, 2019 and
applicable June 18, 2019.
FOR FURTHER INFORMATION CONTACT:
Logan M. Kincheloe at (202) 317–6937
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
Background
The temporary regulations (TD 9865)
that are the subject of this correction are
under sections 245A, 954(c)(6), and
6038 of the Internal Revenue Code.
Need for Correction
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As published June 18, 2019 (84 FR
28398), the temporary regulations (TD
9865; FR 2019–12442) contained errors
that may prove misleading and therefore
need to be corrected.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
Jkt 247001
[FR Doc. 2019–16630 Filed 8–7–19; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
§§ 1.245A–1T through 1.245A–4T
[Reserved]
Internal Revenue Service
Par. 2. Reserved §§ 1.245A–1 through
1.245A–4 are revised to read §§ 1.245A–
1T through 1.245A–4T [Reserved].
26 CFR Part 1
Par. 3. Section 1.245A–5T is amended
by:
■ 1. In the first sentence of paragraph
(c)(3)(i)(B), removing ‘‘a SFC’’ and
adding in its place ‘‘an SFC’’.
■ 2. Adding two sentences at the end of
paragraph (c)(3)(iv).
■ 3. In paragraphs (e)(3)(i)(C)(1) and (2),
removing ‘‘required by paragraph
(e)(3)(iv)’’ and adding in its place
‘‘described in paragraph (e)(3)(i)(D)’’.
■ 4. In paragraph (e)(3)(i)(D), removing
‘‘(e)(3)(iii)’’ and adding in its place
‘‘(e)(3)(i)(C)’’.
■ 5. In paragraph (e)(3)(ii), removing
‘‘amount with’’ and adding in its place
‘‘amount (or, with respect to a lower-tier
CFC, a tiered extraordinary reduction
amount under paragraph (f) of this
section) with’’.
The additions read as follows:
■
[TD 9865]
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
Authority: 26 U.S.C. 7805 * * *
■
Internal Revenue Service
15:42 Aug 07, 2019
Paragraph 1. The authority citation
continues to read in part as follows:
■
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BILLING CODE 4910–13–P
VerDate Sep<11>2014
PART 1—INCOME TAXES
respect to such property during the
disqualified period.
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§ 1.245A–5T Limitation of section 245A
deduction and section 954(c)(6) exception
(temporary).
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(c) * * *
(3) * * *
(iv) * * * Specified property is also
property with respect to which a loss
was recognized during the disqualified
period if the loss is properly allocable
to income not described in section
951A(c)(2)(A)(i)(I) through (V) under the
principles of section 954(b)(5) (specified
loss). If only a portion of the loss
recognized with respect to property
during the disqualified period is
specified loss, then a portion of the
property is treated as specified property
in an amount that bears the same ratio
to the value of the property as the
amount of specified loss bears to the
total amount of loss recognized with
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[TD 9865]
RIN 1545–BO64
Limitation on Deduction for Dividends
Received From Certain Foreign
Corporations and Amounts Eligible for
Section 954 Look-Through Exception;
Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Final temporary regulations;
correction.
AGENCY:
This document contains a
correction to a Treasury Decision 9865,
which was published in the Federal
Register on Tuesday, June 18, 2019.
Treasury Decision 9865 contains
temporary regulations under section
245A of the Internal Revenue Code (the
‘‘Code’’) that limit the dividends
received from current or former
controlled foreign corporations.
DATES: Effective date: These regulations
are effective August 8, 2019 and
applicable June 18, 2019.
FOR FURTHER INFORMATION CONTACT:
Logan M. Kincheloe at (202) 317–6937
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:
Background
The final regulations (TD 9865) that
are the subject of this correction are
issued under sections 245A, 954, and
6038.
Need for Correction
As published, the final regulations
(TD 9865), contains errors that may
prove to be misleading and are in need
of clarification.
Correction to Publication
Accordingly, the final regulations (TD
9865), that are the subject of FR 2019–
12442, in the issue of June 18, 2019, are
corrected as follows:
■ 1. On page 28398, in the third column,
in the tenth line of the second full
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08AUR1
Federal Register / Vol. 84, No. 153 / Thursday, August 8, 2019 / Rules and Regulations
paragraph, ‘‘intangible lowed-taxed’’ is
corrected to read ‘‘intangible lowtaxed’’.
■ 2. On page 28403, in the third column,
in the fifth line of the first partial
paragraph, ‘‘§ 1.245A–5T(g)(3)(iv)’’ is
corrected to read ‘‘§ 1.245A–5T(g)(4)(i)’’.
■ 3. On the same page, in the same
column, in the twelfth line of the first
full paragraph, ‘‘§ 1.245A–5T(g)(5)’’ is
corrected to read ‘‘§ 1.245A–5T(g)(4)(i)’’.
■ 4. On page 28404, in the first column,
under the heading ‘‘A. In General’’, in
the second paragraph, ‘‘Explanations of
Provisions’’ is corrected to read
‘‘Explanation of Provisions’’.
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2019–16631 Filed 8–7–19; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF HOMELAND
SECURITY
Coast Guard
33 CFR Part 100
[Docket Number USCG–2019–0300]
RIN 1625–AA08
Special Local Regulations; Festival of
Sail Duluth 2019, Lake Superior,
Duluth, MN
Coast Guard, DHS.
Temporary final rule.
AGENCY:
ACTION:
The Coast Guard is
establishing a temporary special local
regulation for a designated area of the
Duluth Harbor entrance to Superior Bay
on Lake Superior during the Festival of
Sail 2019 event in Duluth, MN. This
action is necessary to provide for the
safety of life on these navigable waters
around the port of Duluth, MN. This
rulemaking prohibits persons and
vessels from being in the designated
region unless authorized by the Captain
of the Port Duluth or a designated
representative.
SUMMARY:
This rule is effective from 7 a.m.
on August 11, 2019, through 5 p.m. on
August 13, 2019.
ADDRESSES: To view documents
mentioned in this preamble as being
available in the docket, go to https://
www.regulations.gov, type USCG–2019–
0300 in the ‘‘SEARCH’’ box and click
‘‘SEARCH.’’ Click on Open Docket
Folder on the line associated with this
rule.
FOR FURTHER INFORMATION CONTACT: If
you have questions about this
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DATES:
VerDate Sep<11>2014
15:42 Aug 07, 2019
Jkt 247001
rulemaking, call or email Lieutenant
Abbie Lyons, Waterways Management,
MSU Duluth, U.S. Coast Guard;
telephone 218–725–3818, email
Abbie.E.Lyons@uscg.mil.
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
II. Background Information and
Regulatory History
On December 11, 2018 Draw Events
LLC notified the Coast Guard that it will
be conducting a Festival of Sail event in
Duluth, MN from August 11 through
August 13, 2019. The Coast Guard
published a Notice of Proposed
Rulemaking (NPRM) in the Federal
Register on May 8, 2019. A public
comment period was held from May 8,
2019 to July 7, 2019 with no comments
received. A Supplemental Notice of
Proposed Rulemaking (SNPRM) was
submitted to the Federal Register with
a comment period held from July 3,
2019 to July 17, 2019, extending the
Special Local Regulation through the
duration of the event. During the
comment period we received no
comments.
Under 5 U.S.C. 553(d)(3), the Coast
Guard finds that good cause exists for
making this rule effective less than 30
days after publication in the Federal
Register. Delaying the effective date of
this rule would be impracticable
because action is needed during the
Festival of Sail to respond to the
potential safety hazards associated with
increased vessel traffic within Superior
Harbor.
III. Legal Authority and Need for Rule
The Coast Guard is issuing this rule
under authority in 46 U.S.C. 70034. The
Captain of the Port Duluth (COTP) has
determined that potential hazards
associated with increased traffic during
the Festival of Sail starting at 7 a.m. on
August 11, 2019 will be a safety concern
for anyone the designated area. The
likely combination of recreational
vessels, paddling craft, and Tall Ships
present an unacceptable risk of
collisions which could result in serious
injuries or fatalities. This rule is needed
to protect personnel, vessels, and the
marine environment in the navigable
waters within the special local
regulation during the event.
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38867
IV. Discussion of Comments, Changes,
and the Rule
No comments were received on the
SNPRM published July 3, 2019. There
are no changes in the regulatory text of
this rule from the proposed rule in the
SNPRM.
This rule establishes a Special Local
Regulation from 7 a.m. on August 11,
2019 through 5 p.m. on August 13,
2019. The duration of the zone is
intended to protect the safety of vessels
and these navigable waters before,
during, and immediately after the
scheduled Festival of Sail. Only the
designated Tall Ships associated with
the event are permitted within the zone
while it is being enforced. No other
vessels or persons will be permitted to
enter the zone without obtaining
permission from the COTP or a
designated representative during the
enforcement period. The COTP or a
designated representative may be
contacted via VHF Channel 16 or by
telephone at (218) 428–9357. The
regulatory text appears at the end of this
document.
V. Regulatory Analyses
We developed this 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.
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 rule has not
been designated a ‘‘significant
regulatory action,’’ under Executive
Order 12866. Accordingly, this rule 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 availability of the
Superior Harbor entrance as an alternate
entry into Superior Bay, the short time
frame of the special local regulation,
and the estimated number of spectator
vessels around the Duluth Harbor
entrance for the event. We anticipate
that it will have minimal impact on the
economy, will not interfere with other
agencies, will not adversely alter the
budget of any grant or loan recipients,
E:\FR\FM\08AUR1.SGM
08AUR1
Agencies
[Federal Register Volume 84, Number 153 (Thursday, August 8, 2019)]
[Rules and Regulations]
[Pages 38866-38867]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-16631]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9865]
RIN 1545-BO64
Limitation on Deduction for Dividends Received From Certain
Foreign Corporations and Amounts Eligible for Section 954 Look-Through
Exception; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final temporary regulations; correction.
-----------------------------------------------------------------------
SUMMARY: This document contains a correction to a Treasury Decision
9865, which was published in the Federal Register on Tuesday, June 18,
2019. Treasury Decision 9865 contains temporary regulations under
section 245A of the Internal Revenue Code (the ``Code'') that limit the
dividends received from current or former controlled foreign
corporations.
DATES: Effective date: These regulations are effective August 8, 2019
and applicable June 18, 2019.
FOR FURTHER INFORMATION CONTACT: Logan M. Kincheloe at (202) 317-6937
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9865) that are the subject of this
correction are issued under sections 245A, 954, and 6038.
Need for Correction
As published, the final regulations (TD 9865), contains errors that
may prove to be misleading and are in need of clarification.
Correction to Publication
Accordingly, the final regulations (TD 9865), that are the subject
of FR 2019-12442, in the issue of June 18, 2019, are corrected as
follows:
0
1. On page 28398, in the third column, in the tenth line of the second
full
[[Page 38867]]
paragraph, ``intangible lowed-taxed'' is corrected to read ``intangible
low-taxed''.
0
2. On page 28403, in the third column, in the fifth line of the first
partial paragraph, ``Sec. 1.245A-5T(g)(3)(iv)'' is corrected to read
``Sec. 1.245A-5T(g)(4)(i)''.
0
3. On the same page, in the same column, in the twelfth line of the
first full paragraph, ``Sec. 1.245A-5T(g)(5)'' is corrected to read
``Sec. 1.245A-5T(g)(4)(i)''.
0
4. On page 28404, in the first column, under the heading ``A. In
General'', in the second paragraph, ``Explanations of Provisions'' is
corrected to read ``Explanation of Provisions''.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2019-16631 Filed 8-7-19; 8:45 am]
BILLING CODE 4830-01-P