Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups; Hearing, 25378 [2020-08842]

Download as PDF 25378 Federal Register / Vol. 85, No. 85 / Friday, May 1, 2020 / Proposed Rules DESIGNATION] authorizing the exploration or production of oil, gas, or minerals in that area shall be invalid. DEPARTMENT OF THE TREASURY Section 3. Department of Defense Activities 26 CFR Part 1 [REG–105495–19] The prohibitions in § 922.122(a)(2) through (11) do not apply to activities being carried out by the Department of Defense as of the effective date of Sanctuary designation [insert effective date of Sanctuary expansion]. Such activities shall be carried out in a manner that minimizes any adverse impact on Sanctuary resources and qualities. The prohibitions in paragraphs (a)(2) through (11) of this section do not apply to any new activities carried out by the Department of Defense that do not have the potential for any significant adverse impact on Sanctuary resources and qualities. Such activities shall be carried out in a manner that minimizes any adverse impact on Sanctuary resources and qualities. New activities with the potential for significant adverse impact on Sanctuary resources and qualities may be exempted from the prohibitions in paragraphs (a)(2) through (11) of this section by the Director after consultation between the Director and the Department of Defense. If it is determined that an activity may be carried out, such activity shall be carried out in a manner that minimizes any adverse impact on Sanctuary resources and qualities. In the event of threatened or actual destruction of, loss of, or injury to a Sanctuary resource or quality resulting from an untoward incident, including but not limited to spills and groundings, caused by a component of the Department of Defense, the cognizant component shall promptly coordinate with the Director for the purpose of taking appropriate actions to respond to and mitigate the harm and, if possible, restore or replace the Sanctuary resource or quality. Article VI—Alterations to This Designation The terms of designation may be modified only by the same procedures by which the original designation is made, including public hearings, consultation with any appropriate Federal, State, regional and local agencies, review by the appropriate Congressional committees and approval by the Secretary of Commerce or designee. [FR Doc. 2020–08128 Filed 4–30–20; 8:45 am] BILLING CODE 3510–NK–P VerDate Sep<11>2014 08:06 May 01, 2020 Jkt 250001 Internal Revenue Service RIN 1545–BP21 Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups; Hearing Internal Revenue Service (IRS), Treasury. ACTION: Proposed rule; notification of hearing. AGENCY: This document provides a notice of public hearing on proposed regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups. DATES: The public hearing is being held on Wednesday, May 20, 2020, at 10:00 a.m. The IRS must receive speakers’ outlines of the topics to be discussed at the public hearing by Monday, May 11, 2020. If no outlines are received by May 11, 2020, the public hearing will be cancelled. ADDRESSES: The public hearing is being held by teleconference. Individuals who want to testify (by telephone) at the public hearing must send an email to publichearings@irs.gov to receive the telephone number and access code for the hearing. The subject line of the email must contain the regulation number REG–105495–19 and the word TESTIFY. For example, the subject line may say: Request to TESTIFY at Hearing for REG–105495–19. The email should also include a copy of the speaker’s public comments and outline of topics. The email must be received by May 11, 2020. Individuals who want to attend (by telephone) the public hearing must also send an email to publichearings@irs.gov to receive the telephone number and access code for the hearing. The subject line of the email must contain the regulation number REG–105495–19 and the word ATTEND. For example, the subject line may say: Request to ATTEND Hearing for REG–105495–19. The email requesting to attend the public hearing must be received by 5:00 SUMMARY: PO 00000 Frm 00053 Fmt 4702 Sfmt 9990 p.m. two (2) business days before the date that the hearing is scheduled. The telephonic hearing will be made accessible to people with disabilities. To request special assistance during the telephonic hearing please contact the Publications and Regulations Branch of the Office of Associate Chief Counsel (Procedure and Administration) by sending an email to publichearings@ irs.gov (preferred) or by telephone at (202) 317–5177 (not a toll-free number) at least three (3) days prior to the date that the telephonic hearing is scheduled. Any questions regarding speaking at or attending a public hearing may also be emailed to publichearings@irs.gov. Send outline submissions electronically via the Federal eRulemaking Portal at www.regulations.gov (IRS REG–105495– 19). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Jeffrey Cowan at (202) 317- 4924; concerning submissions of comments, the hearing and/access code to attend the hearing by teleconferencing, Regina Johnson at (202) 317–5177 (not toll-free numbers) or publichearings@irs.gov. The subject of the public hearing is the notice of proposed rulemaking REG– 105495–19 that was published in the Federal Register on December 17, 2019, 84 FR 69124. The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments telephonically at the hearing that submitted written comments by February 18, 2020, must submit an outline of the topics to be addressed and the amount of time to be devoted to each topic by May 11, 2020. 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, on Regulations.gov, search IRS and REG– 105495–19, or by emailing your request to publichearings@irs.gov. Please put ‘‘REG–105495–19 Agenda Request’’ in the subject line of the email. SUPPLEMENTARY INFORMATION: Martin V. Franks, Branch Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration). [FR Doc. 2020–08842 Filed 4–30–20; 8:45 am] BILLING CODE 4830–01–P E:\FR\FM\01MYP1.SGM 01MYP1

Agencies

[Federal Register Volume 85, Number 85 (Friday, May 1, 2020)]
[Proposed Rules]
[Page 25378]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08842]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-105495-19]
RIN 1545-BP21


Guidance Related to the Allocation and Apportionment of 
Deductions and Foreign Taxes, Financial Services Income, Foreign Tax 
Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), 
and Consolidated Groups; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Proposed rule; notification of hearing.

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SUMMARY: This document provides a notice of public hearing on proposed 
regulations that provide guidance relating to the allocation and 
apportionment of deductions and creditable foreign taxes, the 
definition of financial services income, foreign tax redeterminations, 
availability of foreign tax credits under the transition tax, and the 
application of the foreign tax credit limitation to consolidated 
groups.

DATES: The public hearing is being held on Wednesday, May 20, 2020, at 
10:00 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Monday, May 11, 2020. If no outlines 
are received by May 11, 2020, the public hearing will be cancelled.

ADDRESSES: The public hearing is being held by teleconference. 
Individuals who want to testify (by telephone) at the public hearing 
must send an email to [email protected] to receive the telephone 
number and access code for the hearing. The subject line of the email 
must contain the regulation number REG-105495-19 and the word TESTIFY. 
For example, the subject line may say: Request to TESTIFY at Hearing 
for REG-105495-19. The email should also include a copy of the 
speaker's public comments and outline of topics. The email must be 
received by May 11, 2020.
    Individuals who want to attend (by telephone) the public hearing 
must also send an email to [email protected] to receive the 
telephone number and access code for the hearing. The subject line of 
the email must contain the regulation number REG-105495-19 and the word 
ATTEND. For example, the subject line may say: Request to ATTEND 
Hearing for REG-105495-19. The email requesting to attend the public 
hearing must be received by 5:00 p.m. two (2) business days before the 
date that the hearing is scheduled.
    The telephonic hearing will be made accessible to people with 
disabilities. To request special assistance during the telephonic 
hearing please contact the Publications and Regulations Branch of the 
Office of Associate Chief Counsel (Procedure and Administration) by 
sending an email to [email protected] (preferred) or by telephone 
at (202) 317-5177 (not a toll-free number) at least three (3) days 
prior to the date that the telephonic hearing is scheduled.
    Any questions regarding speaking at or attending a public hearing 
may also be emailed to [email protected].
    Send outline submissions electronically via the Federal eRulemaking 
Portal at www.regulations.gov (IRS REG-105495-19).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Jeffrey Cowan at (202) 317- 4924; concerning submissions of comments, 
the hearing and/access code to attend the hearing by teleconferencing, 
Regina Johnson at (202) 317-5177 (not toll-free numbers) or 
[email protected].

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking REG-105495-19 that was published in the 
Federal Register on December 17, 2019, 84 FR 69124.
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments telephonically at the hearing that 
submitted written comments by February 18, 2020, must submit an outline 
of the topics to be addressed and the amount of time to be devoted to 
each topic by May 11, 2020.
    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, on Regulations.gov, search 
IRS and REG-105495-19, or by emailing your request to 
[email protected].
    Please put ``REG-105495-19 Agenda Request'' in the subject line of 
the email.

Martin V. Franks,
Branch Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-08842 Filed 4-30-20; 8:45 am]
BILLING CODE 4830-01-P