Rules Regarding Certain Hybrid Arrangements; Correcting Amendment, 48651 [2020-15842]
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Federal Register / Vol. 85, No. 156 / Wednesday, August 12, 2020 / Rules and Regulations
Dated: July 17, 2020.
Lauren K. Roth,
Associate Commissioner for Policy.
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
[FR Doc. 2020–15826 Filed 8–11–20; 8:45 am]
BILLING CODE 4164–01–P
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.267A–5 is amended
by revising paragraph (a)(20)(ii) to read
as follows:
■
DEPARTMENT OF THE TREASURY
Internal Revenue Service
§ 1.267A–5
26 CFR Part 1
[TD 9896]
RIN 1545–BO53
Rules Regarding Certain Hybrid
Arrangements; Correcting Amendment
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
AGENCY:
This document contains
corrections to final regulations Treasury
Decision 9896 that were published in
the Federal Register on Wednesday,
April 8, 2020. The final regulations
providing guidance regarding hybrid
dividends and certain amounts paid or
accrued pursuant to hybrid
arrangements, which generally involve
arrangements whereby U.S. and foreign
tax law classify a transaction or entity
differently for tax purposes.
DATES:
Effective date: This correction is
effective on August 12, 2020.
Applicability dates: For dates of
applicability, see §§ 1.267A–7 and
1.1503(d).
SUMMARY:
FOR FURTHER INFORMATION CONTACT:
Tracy Villecco at (202) 317–6933 or
Tianlin (Laura) Shi at (202) 317–6936
(not toll-free numbers).
SUPPLEMENTARY INFORMATION:
§ 1.267A–7
Background
The final regulations (TD 9896) that
are the subject of this correction are
issued under sections 267A and 1503(d)
of the Code.
Need for Correction
khammond on DSKJM1Z7X2PROD with RULES
As published April 8, 2020 (85 FR
19802), the final regulation (TD 9896;
FR Doc. 2020–05924) contained 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:
VerDate Sep<11>2014
15:56 Aug 11, 2020
Jkt 250001
Definitions and special rules.
(a) * * *
(20) * * *
(ii) Party to a structured arrangement.
A party to a structured arrangement
means a tax resident, a taxable branch,
or an entity that participates in the
structured arrangement. For purposes of
this paragraph (a)(20)(ii), in the case of
an entity, the entity’s participation in a
structured arrangement is imputed to its
investors. However, a tax resident, a
taxable branch or an entity (the relevant
party) is considered to participate in the
structured arrangement only if—
(A) The relevant party (or a related tax
resident or taxable branch, determined
under paragraph (a)(14) of this section
by treating the relevant party as a
specified party) could, based on all the
facts and circumstances, reasonably be
expected to be aware of the hybrid
mismatch; and
(B) The relevant party or one or more
of its investors (or a related tax resident
or taxable branch, determined under
paragraph (a)(14) of this section by
treating the relevant party or an investor
as a specified party) shares in the value
of the tax benefit resulting from the
hybrid mismatch.
*
*
*
*
*
■ Par. 3. Section 1.267A–7 is amended
by revising paragraph (a) to read as
follows:
Applicability dates.
(a) General rule. Except as provided in
paragraph (b) of this section, §§ 1.267A–
1 through 1.267A–6 apply to taxable
years ending on or after December 20,
2018, provided that such taxable years
begin after December 31, 2017.
However, taxpayers may apply the
regulations in §§ 1.267A–1 through
1.267A–6 in their entirety (including by
taking into account paragraph (b) of this
section) for taxable years beginning after
December 31, 2017, and ending before
December 20, 2018. In lieu of applying
the regulations in §§ 1.267A–1 through
1.267A–6 (including paragraph (b) of
this section), taxpayers may apply the
provisions matching §§ 1.267A–1
through 1.267A–6 (including by taking
into account the provision matching
paragraph (b) of this section) from the
Internal Revenue Bulletin (IRB) 2019–03
PO 00000
Frm 00007
Fmt 4700
Sfmt 4700
48651
(https://www.irs.gov/pub/irs-irbs/irb1903.pdf) in their entirety for all taxable
years ending on or before April 8, 2020.
*
*
*
*
*
§ 1.1503(d)–7
[Amended]
Par. 4. Section 1.1503(d)–
7(c)(6)(iii)(A) is amended by removing
‘‘paragraphs’’ and adding ‘‘paragraph’’
in its place.
■
Martin V. Franks,
Chief, Publications and Regulations Branch,
Legal Processing Division, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2020–15842 Filed 8–11–20; 8:45 am]
BILLING CODE 4830–01–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 180
[EPA–HQ–OPP–2019–0232; FRL–10009–42]
Nitrapyrin; Pesticide Tolerances
Environmental Protection
Agency (EPA).
ACTION: Final rule.
AGENCY:
This regulation establishes
tolerances for residues of nitrapyrin in
or on sugar beet molasses, sugar beet
roots, sugar beet tops, rapeseed seed,
and the vegetable, tuberous and corm,
crop subgroup 1C. Dow AgroSciences
LLC requested these tolerances under
the Federal Food, Drug, and Cosmetic
Act (FFDCA).
DATES: This regulation is effective
August 12, 2020. Objections and
requests for hearings must be received
on or before October 13, 2020 and must
be filed in accordance with the
instructions provided in 40 CFR part
178 (see also Unit I.C. of the
SUPPLEMENTARY INFORMATION).
ADDRESSES: The docket for this action,
identified by docket identification (ID)
number EPA–HQ–OPP–2019–0232, is
available at https://www.regulations.gov
or at the Office of Pesticide Programs
Regulatory Public Docket (OPP Docket)
in the Environmental Protection Agency
Docket Center (EPA/DC), West William
Jefferson Clinton Bldg., Rm. 3334, 1301
Constitution Ave. NW, Washington, DC
20460–0001. The Public Reading Room
is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal
holidays. The telephone number for the
Public Reading Room is (202) 566–1744,
and the telephone number for the OPP
Docket is (703) 305–5805.
Please note that due to the public
health emergency the EPA Docket
Center (EPA/DC) and Reading Room
was closed to public visitors on March
SUMMARY:
E:\FR\FM\12AUR1.SGM
12AUR1
]]>Agencies
[Federal Register Volume 85, Number 156 (Wednesday, August 12, 2020)]
[Rules and Regulations]
[Page 48651]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-15842]
=======================================================================
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9896]
RIN 1545-BO53
Rules Regarding Certain Hybrid Arrangements; Correcting Amendment
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendments.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to final regulations
Treasury Decision 9896 that were published in the Federal Register on
Wednesday, April 8, 2020. The final regulations providing guidance
regarding hybrid dividends and certain amounts paid or accrued pursuant
to hybrid arrangements, which generally involve arrangements whereby
U.S. and foreign tax law classify a transaction or entity differently
for tax purposes.
DATES:
Effective date: This correction is effective on August 12, 2020.
Applicability dates: For dates of applicability, see Sec. Sec.
1.267A-7 and 1.1503(d).
FOR FURTHER INFORMATION CONTACT: Tracy Villecco at (202) 317-6933 or
Tianlin (Laura) Shi at (202) 317-6936 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9896) that are the subject of this
correction are issued under sections 267A and 1503(d) of the Code.
Need for Correction
As published April 8, 2020 (85 FR 19802), the final regulation (TD
9896; FR Doc. 2020-05924) contained 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 1.267A-5 is amended by revising paragraph (a)(20)(ii)
to read as follows:
Sec. 1.267A-5 Definitions and special rules.
(a) * * *
(20) * * *
(ii) Party to a structured arrangement. A party to a structured
arrangement means a tax resident, a taxable branch, or an entity that
participates in the structured arrangement. For purposes of this
paragraph (a)(20)(ii), in the case of an entity, the entity's
participation in a structured arrangement is imputed to its investors.
However, a tax resident, a taxable branch or an entity (the relevant
party) is considered to participate in the structured arrangement only
if--
(A) The relevant party (or a related tax resident or taxable
branch, determined under paragraph (a)(14) of this section by treating
the relevant party as a specified party) could, based on all the facts
and circumstances, reasonably be expected to be aware of the hybrid
mismatch; and
(B) The relevant party or one or more of its investors (or a
related tax resident or taxable branch, determined under paragraph
(a)(14) of this section by treating the relevant party or an investor
as a specified party) shares in the value of the tax benefit resulting
from the hybrid mismatch.
* * * * *
0
Par. 3. Section 1.267A-7 is amended by revising paragraph (a) to read
as follows:
Sec. 1.267A-7 Applicability dates.
(a) General rule. Except as provided in paragraph (b) of this
section, Sec. Sec. 1.267A-1 through 1.267A-6 apply to taxable years
ending on or after December 20, 2018, provided that such taxable years
begin after December 31, 2017. However, taxpayers may apply the
regulations in Sec. Sec. 1.267A-1 through 1.267A-6 in their entirety
(including by taking into account paragraph (b) of this section) for
taxable years beginning after December 31, 2017, and ending before
December 20, 2018. In lieu of applying the regulations in Sec. Sec.
1.267A-1 through 1.267A-6 (including paragraph (b) of this section),
taxpayers may apply the provisions matching Sec. Sec. 1.267A-1 through
1.267A-6 (including by taking into account the provision matching
paragraph (b) of this section) from the Internal Revenue Bulletin (IRB)
2019-03 (https://www.irs.gov/pub/irs-irbs/irb19-03.pdf) in their
entirety for all taxable years ending on or before April 8, 2020.
* * * * *
Sec. 1.1503(d)-7 [Amended]
0
Par. 4. Section 1.1503(d)-7(c)(6)(iii)(A) is amended by removing
``paragraphs'' and adding ``paragraph'' in its place.
Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division,
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2020-15842 Filed 8-11-20; 8:45 am]
BILLING CODE 4830-01-P
