Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits, 44693-44694 [2019-18348]

Download as PDF Federal Register / Vol. 84, No. 166 / Tuesday, August 27, 2019 / Rules and Regulations imports of the article that is the subject of the petition. * * * * * (j) The names of any domestic producers of the article, if available. * * * * * (n) A certification from the petitioner that the information supplied is complete and correct to the best of the petitioner’s knowledge and belief, and an acknowledgement from the petitioner that the information submitted is subject to audit and verification by the Commission. * * * * * 3. Amend § 220.7 by revising the section heading to read as follows: ■ § 220.7 Properly filed petition; identical and overlapping petitions from same petitioner. * * * * * 4. Amend § 220.9 by revising paragraph (a) to read as follows: ■ § 220.9 Withdrawal of petitions, amendments to petitions. (a) Withdrawal of petitions. A petitioner may withdraw a petition for duty suspension or reduction filed under this part no later than 30 days after the Commission submits its preliminary report, as described in § 220.12. It shall do so by notifying the Commission through the Commission’s designated secure web portal of its withdrawal and the notification shall include the name of the petitioner, the Commission identification number for the petition, and the HTS number for the article concerned. * * * * * ■ 5. Revise § 220.10 to read as follows: § 220.10 Commission publication and public availability of petitions. jspears on DSK3GMQ082PROD with RULES Not later than 30 days after expiration of the 60-day period for filing petitions for duty suspensions and reductions, the Commission will publish on its website the petitions for duty suspensions and reductions submitted under § 220.3 that were timely filed and contain the information required under § 220.5. When circumstances allow, the Commission may post such petitions on its website earlier than 30 days after expiration of the 60-day period for filing petitions. § § 220.11 through 220.14 [Redesignated as §§ 220.12 through 220.15] 6. Redesignate §§ 220.11 through 220.14 as §§ 220.12 through 220.15. ■ 7. Add a new § 220.11 to read as follows: ■ VerDate Sep<11>2014 17:38 Aug 26, 2019 Jkt 247001 § 220.11 Public comment period. (a) Time for filing. Not later than 30 days after expiration of the 60-day period for filing petitions, the Commission will also publish in the Federal Register and on its website a notice requesting members of the public to submit comments on the petitions for duty suspensions and reductions. To be considered, such comments must be filed through the Commission’s secure web portal during the 45-day period following publication of the Commission’s notice requesting comments from members of the public. For purposes of this section, all petitions posted by the Commission on its website, whether or not posted early, shall be deemed to be officially published by the Commission on its website on the date of publication of the notice seeking written comments from members of the public on the petitions. (b) In general. The comment shall include the following information: (1) The name, telephone number, and postal and email address of the commenter, and if appropriate, its representative in the matter; (2) A statement as to whether the commenter is a U.S. producer, importer, government entity, trade association or group, or other; (3) A statement as to whether the comment supports the petition; objects to the petition; or takes no position with respect to the petitions/provides other comment; (4) If the commenter is an importer, a list of the leading source countries of the product; (5) A certification from the commenter that the information supplied is complete and correct to the best of the commenter’s knowledge and belief, and an acknowledgement from the commenter that the information submitted is subject to audit and verification by the Commission; and (6) Comment formats may be constrained in size, length, attachments, file type, etc., by system limitations in the Commission’s secure web portal. See the Commission’s Handbook on MTB Filing Procedures as posted on the Commission’s website for further information. (c) Comments from domestic producers. Comments from a firm claiming to be a domestic producer, as defined in § 220.2(g), shall also include: (1) A description of the product alleged to be identical, like, or directly competitive with the product that is the subject of the petition; (2) The Chemical Abstracts Service registry number for the product (if applicable); PO 00000 Frm 00013 Fmt 4700 Sfmt 4700 44693 (3) A statement as to whether an identical, like, or directly competitive product was produced in the current calendar year and, if not, the year in which the product was last produced or in which production is expected to begin within the United States; (4) A statement as to whether such product is generally available for sale, and if not, an explanation of its lack of availability for sale; and/or (5) The physical address(es) for the location(s) of the production facility(ies) producing the product within the United States; and (6) Evidence demonstrating the existence of domestic production (e.g., catalogs, press releases, marketing materials, specification sheets, copies of orders for the product). (d) Additional comment period. The Commission may provide additional opportunity for public comment and, if so, will announce that comment period in the Federal Register. ■ 8. Amend newly redesignated § 220.12 by revising paragraph (b)(2) to read as follows: § 220.12 Commission preliminary report. * * * * * (b) * * * (2) A list of petitions for duty suspensions and reductions for which the Commission recommends technical corrections in order to meet the requirements of the Act, with the correction specified. * * * * * By order of the Commission. Issued: August 16, 2019. Lisa Barton, Secretary to the Commission. [FR Doc. 2019–18008 Filed 8–26–19; 8:45 am] BILLING CODE 7020–02–P DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9866] Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. AGENCY: This document contains corrections to Treasury Decision 9866, which was published in the Federal Register on Friday, June 21, 2019. Treasury Decision 9866 contained final SUMMARY: E:\FR\FM\27AUR1.SGM 27AUR1 44694 Federal Register / Vol. 84, No. 166 / Tuesday, August 27, 2019 / Rules and Regulations regulations under section 951A of the Internal Revenue Code that provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain United States shareholders of foreign corporations. Effective date: These regulations are effective on August 27, 2019. Applicability date: June 21, 2019. adding ‘‘paragraph (c)(4)(iii)(C)’’ in its place. Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, Procedure and Administration. [FR Doc. 2019–18348 Filed 8–26–19; 8:45 am] DATES: BILLING CODE 4830–01–P FOR FURTHER INFORMATION CONTACT: DEPARTMENT OF HOMELAND SECURITY Jorge M. Oben at (202) 317–6934 (not a toll free number). Coast Guard SUPPLEMENTARY INFORMATION: 33 CFR Part 100 Background The final regulation (TD 9866) that is the subject of this correction is under section 951A of the Internal Revenue Code. Need for Correction As published in June 21, 2019 (84 FR 29288), the final regulations (TD 9866; FR 2019–12437) 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. 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 * * * § 1.951A–2 [Amended] Par. 2. Section 1.951A–2 is amended by: ■ a. In the second sentence of paragraph (c)(4)(iv)(A)(2)(i), removing the language ‘‘paragraph (c)(4)(ii)(A)’’ and adding ‘‘paragraph (c)(4)(iii)(A)’’ in its place; ■ b. In the third sentence of paragraph (c)(4)(iv)(A)(2)(ii), removing the language ‘‘paragraph (c)(4)(ii)(B)’’ and adding ‘‘paragraph (c)(4)(iii)(B)’’ in its place; and ■ c. In paragraph (c)(4)(iv)(C)(2)(iii): ■ i. In the third sentence, removing the language ‘‘paragraph (c)(4)(ii)(B)’’ and adding ‘‘paragraph (c)(4)(iii)(B)’’ in its place; and ■ ii. In the fourth sentence, removing the language ‘‘paragraph (c)(4)(iii)’’ and jspears on DSK3GMQ082PROD with RULES ■ VerDate Sep<11>2014 17:38 Aug 26, 2019 Jkt 247001 [Docket No USCG–2019–0684] RIN 1625–AA08 Special Local Regulation; Frogtown Regatta, Maumee River, Toledo, OH Coast Guard, DHS. Temporary final rule. AGENCY: ACTION: The Coast Guard is establishing a temporary special local regulation for all navigable waters of the Maumee River, Toledo, OH from the Martin Luther King Jr. Memorial Bridge at Maumee River mile 4.30 to the Michael DiSalle Bridge at river mile 6.73. This regulated area is necessary to protect spectators and vessels from potential hazards associated with the Frogtown Regatta. Entry of vessels or persons into this regulated area is prohibited unless specifically authorized by the Captain of the Port Detroit, or a designated representative. DATES: This temporary final rule is effective from 7 a.m. through 5 p.m. on September 28, 2019. ADDRESSES: To view documents mentioned in this preamble as being available in the docket, go to https:// www.regulations.gov, type USCG–2019– 0684 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 rule, call or email MSTC Allie Lee, Waterways Department, Marine Safety Unit Toledo, Coast Guard; telephone (419) 418–6023, email Allie.L.Lee@uscg.mil. SUPPLEMENTARY INFORMATION: SUMMARY: 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 PO 00000 Frm 00014 Fmt 4700 Sfmt 4700 II. Background Information and Regulatory History The Coast Guard is issuing this temporary final rule without prior notice and opportunity to comment pursuant to authority under section 4(a) of the Administrative Procedure Act (APA) (5 U.S.C. 553(b)). This provision authorizes an agency to issue a rule without prior notice and opportunity to comment when the agency for good cause finds that those procedures are ‘‘impracticable, unnecessary, or contrary to the public interest.’’ Under 5 U.S.C. 553(b)(B), the Coast Guard finds that good cause exists for not publishing a notice of proposed rulemaking (NPRM) with respect to this rule because doing so would be impracticable. The Coast Guard did not receive the final details of this regatta in time to publish an NPRM. As such, it is impracticable to publish an NPRM because we lack sufficient time to provide a reasonable comment period and then consider those comments before issuing the rule. 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. Waiting for a 30-day effective period to run is impracticable and contrary to the public interest for the reasons discussed in the preceding paragraph. 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 Detroit (COTP) has determined that potential hazard associated with regatta from 7 a.m. through 5 p.m. on September 28, 2019 will be a safety concern to anyone within waters of the Maumee river, Toledo, OH from the Martin Luther King Jr. Memorial Bridge at river mile 4.30 to the Michael DiSalle Bridge at river mile 6.73. This rule is needed to protect personnel, vessels, and the marine environment in the navigable waters within the safety zone while the regatta occurs. IV. Discussion of the Rule This rule establishes a safety zone from 7 a.m. through 5 p.m. on September 28, 2019. The safety zone will encompass all U.S. navigable waters of the Maumee river, Toledo, OH from the Martin Luther King Jr. Memorial Bridge at river mile 4.30 to the Michael DiSalle Bridge at river mile 6.73. No vessel or person will be permitted to enter the safety zone without obtaining permission from the COTP or a designated representative. The Coast Guard will patrol the regatta area under the direction of the E:\FR\FM\27AUR1.SGM 27AUR1

Agencies

[Federal Register Volume 84, Number 166 (Tuesday, August 27, 2019)]
[Rules and Regulations]
[Pages 44693-44694]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-18348]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9866]


Guidance Related to Section 951A (Global Intangible Low-Taxed 
Income) and Certain Guidance Related to Foreign Tax Credits

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

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SUMMARY: This document contains corrections to Treasury Decision 9866, 
which was published in the Federal Register on Friday, June 21, 2019. 
Treasury Decision 9866 contained final

[[Page 44694]]

regulations under section 951A of the Internal Revenue Code that 
provide guidance to determine the amount of global intangible low-taxed 
income included in the gross income of certain United States 
shareholders of foreign corporations.

DATES: Effective date: These regulations are effective on August 27, 
2019.
    Applicability date: June 21, 2019.

FOR FURTHER INFORMATION CONTACT: Jorge M. Oben at (202) 317-6934 (not a 
toll free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulation (TD 9866) that is the subject of this 
correction is under section 951A of the Internal Revenue Code.

Need for Correction

    As published in June 21, 2019 (84 FR 29288), the final regulations 
(TD 9866; FR 2019-12437) 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.

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 * * *


Sec.  1.951A-2   [Amended]

0
Par. 2. Section 1.951A-2 is amended by:
0
a. In the second sentence of paragraph (c)(4)(iv)(A)(2)(i), removing 
the language ``paragraph (c)(4)(ii)(A)'' and adding ``paragraph 
(c)(4)(iii)(A)'' in its place;
0
b. In the third sentence of paragraph (c)(4)(iv)(A)(2)(ii), removing 
the language ``paragraph (c)(4)(ii)(B)'' and adding ``paragraph 
(c)(4)(iii)(B)'' in its place; and
0
c. In paragraph (c)(4)(iv)(C)(2)(iii):
0
i. In the third sentence, removing the language ``paragraph 
(c)(4)(ii)(B)'' and adding ``paragraph (c)(4)(iii)(B)'' in its place; 
and
0
ii. In the fourth sentence, removing the language ``paragraph 
(c)(4)(iii)'' and adding ``paragraph (c)(4)(iii)(C)'' in its place.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, Procedure and Administration.
[FR Doc. 2019-18348 Filed 8-26-19; 8:45 am]
 BILLING CODE 4830-01-P

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