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; Correction, 29368-29369 [2020-08994]

Download as PDF jbell on DSKJLSW7X2PROD with PROPOSALS 29368 Federal Register / Vol. 85, No. 95 / Friday, May 15, 2020 / Proposed Rules sharing and coordination with relevant agencies and entities concerning the implementation or status of emerging threats, monitor implementation of Emerging Threat Response Plans, and coordinate the development and implementation of reporting systems to support performance measurement and adherence to the plan. Agencies identified in an Emerging Threat Response Plan are required to submit a report to the Coordinator on implementation of the plan within 180 days of designation. Upon making an emerging threats designation, the ONDCP Director is required to evaluate whether a media campaign to address the threat is appropriate. If the Director determines that a media campaign is warranted and enough appropriations are available for that purpose, the Director will conduct a national antidrug media campaign in accordance with the requirements of 21 U.S.C. 1708(f). The Director must ensure that the media campaign is evidence-based and accurate, meets accepted standards for public awareness campaigns, and uses effective strategies. ONDCP seeks comments about the relative costs and benefits of designating emerging drug threats and implementing response plans to address such threats. What activities would federal agencies, state, local and tribal governments, health care providers and other entities be required to incur as a result of an emerging drug threat designation, and what would those activities cost? What activities would federal agencies, state, local and tribal governments, health care providers and other entities take voluntarily as result of an emerging drug threat designation, and what would those activities cost? What benefits, such as lives saved and improved public health outcomes, would result from an emerging drug threat designation? Information submitted should include any negative or positive economic effects that could result from promulgation. 5. Effectiveness of Alternative Approaches: How can ONDCP best accomplish its goal of monitoring and identifying emerging drug threats in the United States? What other approaches to designating emerging drug threats should ONDCP consider in carrying out its responsibilities under the SUPPORT Act? Interested parties are invited to submit comments on any or all of these and other pertinent issues related to the development of criteria for designating or terminating the designation of emerging drug threats. ONDCP appreciates any and all comments, but those most useful and likely to VerDate Sep<11>2014 16:25 May 14, 2020 Jkt 250001 influence decisions on the proposed criteria will be those that are either informed by medical, public health, or law enforcement research on evidencebased methods for monitoring or identifying drug trends or involve personal experience with drug misuse and addiction. DEPARTMENT OF THE TREASURY V. Statutory and Executive Order Review 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; Correction This ANPRM has been drafted and reviewed in accordance with Executive Order 12866, ‘‘Regulatory Planning and Review,’’ section 1(b), The Principles of Regulation; Executive Order 13563, ‘‘Improving Regulation and Regulatory Review,’’ section 1(b), General Principles of Regulation; and Executive Order 13771, ‘‘Reducing Regulation and Controlling Regulatory Costs.’’ The Office of Management and Budget (OMB) has determined that this ANPRM is a significant regulatory action under Executive Order 12866, section 3(f), and accordingly this ANPRM has been reviewed by OMB. Pursuant to guidance issued by OMB, the requirements of E.O. 13771 do not apply to this ANPRM. This action does not propose or impose any requirements. ONDCP is merely collecting information and data on the possible economic impact that may occur as a direct or indirect result of promulgation of emerging drug threats criteria. The requirements of the Regulatory Flexibility Act (RFA) do not apply to this action because, at this stage, it is an ANPRM and not ‘‘rule’’ as defined in 5 U.S.C. 601. Following review of the comments received in response to this ANPRM, when ONDCP decides to proceed with a notice of proposed rulemaking regarding this matter, ONDCP will conduct all relevant analyses as required by statute or Executive Order. This ANPRM was prepared under the direction of James W. Carroll, Jr., Director, Office of National Drug Control Policy, 1800 G Street NW, 9th Floor, Washington, DC 20006. It is issued pursuant to section 8218(c) of the SUPPORT for Patients and Communities Act, 21 U.S.C. 1708(c). Michael J. Passante, Acting General Counsel. [FR Doc. 2020–09469 Filed 5–14–20; 8:45 am] BILLING CODE 3280–F5–P PO 00000 Frm 00021 Fmt 4702 Sfmt 4702 Internal Revenue Service 26 CFR Parts 1 and 301 [REG–105495–19] RIN 1545–BP21 Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking; correction. AGENCY: This document contains a correction to a notice of proposed rulemaking (REG–105495–19) that was published in the Federal Register on December 17, 2019. The proposed regulations 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: Written or electronic comments and requests for a public hearing were being accepted and must have been received by February 18, 2020. A telephonic public hearing has been scheduled for May 20, 2020. FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Jeffrey P. Cowan, (202) 317–4924. Regarding the public hearing Regina Johnson at 202–317–5177 or email publichearings@irs.gov. SUPPLEMENTARY INFORMATION: SUMMARY: Background The proposed regulations that are the subject of this correction are under section 861, 904, and 960 of the Internal Revenue Code. Need for Correction As published, the notice of proposed rulemaking (REG–105495–19) contains errors which may prove to be misleading and need to be clarified. Correction of Publication Accordingly, the notice of proposed rulemaking (REG–105495–19) that was the subject of FR Doc. 2019–24847, published at 84 FR 69124 (December 17, 2019), is corrected as follows: 1. On page 69130, third column, the last line of the first partial paragraph, E:\FR\FM\15MYP1.SGM 15MYP1 Federal Register / Vol. 85, No. 95 / Friday, May 15, 2020 / Proposed Rules the language ‘‘§ 1.861–17(d)(4)(v)’’ is corrected to read ‘‘§ 1.861–17(d)(4)(i)’’. 2. On page 69134, first column, the second line from the bottom of the page the language ‘‘245A(g)’’ is corrected to read ‘‘245A(d)’’. 3. On page 69139, third column, the eighth line of the second paragraph under the caption ‘‘Applicability Dates’’, the language ‘‘January 1, 2020,’’ is corrected to read ‘‘January 1, 2020 (or taxpayers that are on the sales method only for the last taxable year that begins before January 1, 2020),’’. 4. On page 69139, third column, the 10th line of the second paragraph under the caption ‘‘Applicability Dates’’, the language ‘‘consistently’’ is corrected to read ‘‘consistently with respect to such taxable year and any subsequent year’’. § 1.861–17 [Corrected] 5. On page 69156, the third column, in § 1.861–17, the third line from the bottom of paragraph (g)(3)(i)(A), the language ‘‘7(b)(1))’’ is corrected to read ‘‘7(b)(1)(ii)’’. ■ 6. On page 69157, the first column, in § 1.861–17, in the second line of paragraph (g)(3)(ii)(B)(3), the language ‘‘(d)(5)(v)’’ is corrected to read (d)(4)(v)’’. ■ 7. On page 69157, the second column, in § 1.861–17, in the seventh line from the bottom of paragraph (g)(4)(ii)(A), the language ‘‘354’’ is corrected to read ‘‘364’’. ■ § 1.960–1 [Corrected] 8. On page 69177, the second column, in § 1.960–1, third line from the bottom of paragraph (d)(3)(ii)(A), the language ‘‘branch,’’ is corrected to read ‘‘branch from the foreign branch owner,’’. ■ Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). [FR Doc. 2020–08994 Filed 5–14–20; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 100 jbell on DSKJLSW7X2PROD with PROPOSALS To view the docket for this withdrawn rulemaking, go to https:// www.regulations.gov, type USCG–2020– 0074 in the ‘‘SEARCH’’ box and click ‘‘SEARCH.’’ Click on Open Docket Folder on the line associated with this rule. ADDRESSES: If you have questions about this notice, call or email Mr. Ron Houck, Waterways Management Division, U.S. Coast Guard Sector Maryland-National Capital Region; telephone 410–576– 2674, email Ronald.L.Houck@uscg.mil. FOR FURTHER INFORMATION CONTACT: SUPPLEMENTARY INFORMATION: Background On January 31, 2020, we published a notice of proposed rulemaking entitled ‘‘Special Local Regulation; Choptank River, Between Trappe and Cambridge, MD’’ in the Federal Register (85 FR 5608). The rulemaking concerned the Coast Guard’s proposal to establish temporary special local regulations for certain waters of the Choptank River, between Trappe, MD, and Cambridge, MD, effective from 9 a.m. through 1 p.m. on May 30, 2020. This action was necessary to provide for the safety of life on these waters during an open water swim event. This rulemaking would have prohibited persons and vessels from entering the regulated area unless authorized by the Captain of the Port Maryland-National Capital Region or the Coast Guard Patrol Commander. The proposed rule is being withdrawn due to a regulated area no longer being necessary following a cancellation of the swim by the event sponsor. Special Local Regulations; Marine Events Within the Fifth Coast Guard District Coast Guard, DHS. Notice of proposed rulemaking; withdrawal. AGENCY: ACTION: 16:25 May 14, 2020 The Coast Guard is withdrawing the proposed rule published January 31, 2020, as of May 15, 2020. DATES: Withdrawal [Docket No. USCG–2020–0074] VerDate Sep<11>2014 The Coast Guard is withdrawing its proposed rule to establish temporary special local regulations for certain waters of the Choptank River. The rulemaking was initiated to establish a special local regulations during the ‘‘Maryland Freedom Swim,’’ a marine event to be held on certain navigable waters of the Choptank River between Trappe, MD, and Cambridge, MD, on May 30, 2020. The proposed rule is being withdrawn because it is no longer necessary. The event sponsor has cancelled the swim event. SUMMARY: Jkt 250001 Authority We issue this notice of withdrawal under the authority of 46 U.S.C. 70034. PO 00000 Frm 00022 Fmt 4702 Sfmt 4702 29369 Dated: May 5, 2020. Joseph B. Loring, Captain, U.S. Coast Guard, Captain of the Port Maryland-National Capital Region. [FR Doc. 2020–10203 Filed 5–14–20; 8:45 am] BILLING CODE 9110–04–P ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 52 [EPA–R10–OAR–2016–0057; FRL–10007– 86–Region 10] Air Plan Approval; OR; 2010 Sulfur Dioxide NAAQS Interstate Transport Requirements Environmental Protection Agency (EPA). ACTION: Proposed rule. AGENCY: The Environmental Protection Agency (EPA) proposes to approve the State Implementation Plan (SIP) submission from Oregon as meeting certain Clean Air Act (CAA) interstate transport requirements for the 2010 1hour Sulfur Dioxide (SO2) National Ambient Air Quality Standards (NAAQS). Specifically, the EPA proposes to find that emissions from Oregon sources will not contribute significantly to nonattainment or interfere with the maintenance of the 2010 1-hour SO2 NAAQS in any other state. DATES: Comments must be received on or before June 15, 2020. ADDRESSES: Submit your comments, identified by Docket ID No EPA–R10– OAR–2016–0057 at https:// www.regulations.gov. Follow the online instructions for submitting comments. Once submitted, comments cannot be edited or removed from https:// www.regulations.gov. The EPA may publish any comment received to its public docket. Do not electronically submit any information you consider to be Confidential Business Information (CBI) or other information the disclosure of which is restricted by statute. Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points you wish to make. The EPA will generally not consider comments or comment contents located outside of the primary submission (i.e. on the web, cloud, or other file sharing system). For additional submission methods, the full EPA public comment policy, information about CBI or multimedia submissions, and general guidance on SUMMARY: E:\FR\FM\15MYP1.SGM 15MYP1

Agencies

[Federal Register Volume 85, Number 95 (Friday, May 15, 2020)]
[Proposed Rules]
[Pages 29368-29369]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08994]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[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; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; correction.

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

SUMMARY: This document contains a correction to a notice of proposed 
rulemaking (REG-105495-19) that was published in the Federal Register 
on December 17, 2019. The proposed regulations 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: Written or electronic comments and requests for a public hearing 
were being accepted and must have been received by February 18, 2020. A 
telephonic public hearing has been scheduled for May 20, 2020.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Jeffrey P. Cowan, (202) 317-4924. Regarding the public hearing Regina 
Johnson at 202-317-5177 or email [email protected].

SUPPLEMENTARY INFORMATION: 

Background

    The proposed regulations that are the subject of this correction 
are under section 861, 904, and 960 of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed rulemaking (REG-105495-19) 
contains errors which may prove to be misleading and need to be 
clarified.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-105495-19) that 
was the subject of FR Doc. 2019-24847, published at 84 FR 69124 
(December 17, 2019), is corrected as follows:
    1. On page 69130, third column, the last line of the first partial 
paragraph,

[[Page 29369]]

the language ``Sec.  1.861-17(d)(4)(v)'' is corrected to read ``Sec.  
1.861-17(d)(4)(i)''.
    2. On page 69134, first column, the second line from the bottom of 
the page the language ``245A(g)'' is corrected to read ``245A(d)''.
    3. On page 69139, third column, the eighth line of the second 
paragraph under the caption ``Applicability Dates'', the language 
``January 1, 2020,'' is corrected to read ``January 1, 2020 (or 
taxpayers that are on the sales method only for the last taxable year 
that begins before January 1, 2020),''.
    4. On page 69139, third column, the 10th line of the second 
paragraph under the caption ``Applicability Dates'', the language 
``consistently'' is corrected to read ``consistently with respect to 
such taxable year and any subsequent year''.


Sec.  1.861-17   [Corrected]

0
5. On page 69156, the third column, in Sec.  1.861-17, the third line 
from the bottom of paragraph (g)(3)(i)(A), the language ``7(b)(1))'' is 
corrected to read ``7(b)(1)(ii)''.
0
6. On page 69157, the first column, in Sec.  1.861-17, in the second 
line of paragraph (g)(3)(ii)(B)(3), the language ``(d)(5)(v)'' is 
corrected to read (d)(4)(v)''.
0
7. On page 69157, the second column, in Sec.  1.861-17, in the seventh 
line from the bottom of paragraph (g)(4)(ii)(A), the language ``354'' 
is corrected to read ``364''.


Sec.  1.960-1   [Corrected]

0
8. On page 69177, the second column, in Sec.  1.960-1, third line from 
the bottom of paragraph (d)(3)(ii)(A), the language ``branch,'' is 
corrected to read ``branch from the foreign branch owner,''.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2020-08994 Filed 5-14-20; 8:45 am]
 BILLING CODE 4830-01-P