Base Erosion and Anti-Abuse Tax; Correcting Amendment, 49595 [2020-16383]

Download as PDF Federal Register / Vol. 85, No. 158 / Friday, August 14, 2020 / Rules and Regulations ‘‘Special Taxes and Taxpayers’’ and following § 1.1502–55. * * * * * DEPARTMENT OF THE TREASURY Internal Revenue Service Martin V. Franks, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). 26 CFR Part 1 [TD 9885] RIN 1545–BO56 [FR Doc. 2020–16383 Filed 8–13–20; 8:45 am] Base Erosion and Anti-Abuse Tax; Correcting Amendment BILLING CODE 4830–01–P Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. PENSION BENEFIT GUARANTY CORPORATION AGENCY: This document contains corrections to final regulations (TD 9885) that were published in the Federal Register on Friday, December 6, 2019. The final regulations implementing the base erosion and antiabuse tax, designed to prevent the reduction of tax liability by certain large corporate taxpayers through certain payments made to foreign related parties and certain tax credits. DATES: Effective date: The final regulations are effective on August 14, 2020. Applicability date: December 6, 2019. FOR FURTHER INFORMATION CONTACT: Sarah Hoyt at (202) 317–6848 or Julie Wang at (202) 317–6975 (not a toll-free number). SUPPLEMENTARY INFORMATION: SUMMARY: Background The final regulations (TD 9885) that are the subject of this correction are issued under § 1.1.502–59A of the Internal Revenue Code. Need for Correction As published, December 6, 2019 (84 FR 66968) the final regulations (TD 9885; FR DOC. 2019–25744) contains an error that needs 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: khammond on DSKJM1Z7X2PROD with RULES ■ Authority: 26 U.S.C. 7805 * * * § 1.1.502–59A [Transferred] Par. 2. Section 1.1502–59A is amended by transferring the section underneath the undesignated heading ■ VerDate Sep<11>2014 16:38 Aug 13, 2020 Jkt 250001 29 CFR Part 4022 Benefits Payable in Terminated SingleEmployer Plans; Interest Assumptions for Paying Benefits Pension Benefit Guaranty Corporation. ACTION: Final rule. AGENCY: This final rule amends the Pension Benefit Guaranty Corporation’s regulation on Benefits Payable in Terminated Single-Employer Plans to prescribe certain interest assumptions under the regulation for plans with valuation dates in September 2020. These interest assumptions are used for paying certain benefits under terminating single-employer plans covered by the pension insurance system administered by PBGC. DATES: Effective September 1, 2020. FOR FURTHER INFORMATION CONTACT: Gregory Katz (katz.gregory@pbgc.gov), Attorney, Regulatory Affairs Division, Pension Benefit Guaranty Corporation, 1200 K Street NW, Washington, DC 20005, (202) 229–3829. (TTY users may call the Federal relay service toll-free at 1–800–877–8339 and ask to be connected to (202) 229–3829.) SUPPLEMENTARY INFORMATION: PBGC’s regulation on Benefits Payable in Terminated Single-Employer Plans (29 CFR part 4022) prescribes actuarial assumptions—including interest assumptions—for paying plan benefits under terminated single-employer plans covered by title IV of the Employee Retirement Income Security Act of 1974 (ERISA). The interest assumptions in the regulation are also published on PBGC’s website (https://www.pbgc.gov). PBGC uses the interest assumptions in appendix B to part 4022 (‘‘Lump Sum Interest Rates for PBGC Payments’’) to determine whether a benefit is payable as a lump sum and to determine the amount to pay. Because some privatesector pension plans use these interest rates to determine lump sum amounts payable to plan participants (if the resulting lump sum is larger than the SUMMARY: PO 00000 Frm 00007 Fmt 4700 Sfmt 4700 49595 amount required under section 417(e)(3) of the Internal Revenue Code and section 205(g)(3) of ERISA), these rates are also provided in appendix C to part 4022 (‘‘Lump Sum Interest Rates for Private-Sector Payments’’). This final rule updates appendices B and C of the benefit payments regulation to provide the rates for September 2020 measurement dates. The September 2020 lump sum interest assumptions will be 0.00 percent for the period during which a benefit is (or is assumed to be) in pay status and 4.00 percent during any years preceding the benefit’s placement in pay status. In comparison with the interest assumptions in effect for August 2020, these assumptions represent no change in the immediate rate and are otherwise unchanged. PBGC updates appendices B and C each month. PBGC has determined that notice and public comment on this amendment are impracticable and contrary to the public interest. This finding is based on the need to issue new interest assumptions promptly so that they are available for plans that rely on our publication of them each month to calculate lump sum benefit amounts. Because of the need to provide immediate guidance for the payment of benefits under plans with valuation dates during September 2020, PBGC finds that good cause exists for making the assumptions set forth in this amendment effective less than 30 days after publication. PBGC has determined that this action is not a ‘‘significant regulatory action’’ under the criteria set forth in Executive Order 12866. Because no general notice of proposed rulemaking is required for this amendment, the Regulatory Flexibility Act of 1980 does not apply. See 5 U.S.C. 601(2). List of Subjects in 29 CFR Part 4022 Employee benefit plans, Pension insurance, Pensions, Reporting and recordkeeping requirements. In consideration of the foregoing, 29 CFR part 4022 is amended as follows: PART 4022—BENEFITS PAYABLE IN TERMINATED SINGLE-EMPLOYER PLANS 1. The authority citation for part 4022 continues to read as follows: ■ Authority: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, rate set 323 is added at the end of the table to read as follows: ■ E:\FR\FM\14AUR1.SGM 14AUR1

Agencies

[Federal Register Volume 85, Number 158 (Friday, August 14, 2020)]
[Rules and Regulations]
[Page 49595]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-16383]



[[Page 49595]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9885]
RIN 1545-BO56


Base Erosion and Anti-Abuse Tax; Correcting Amendment

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

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SUMMARY: This document contains corrections to final regulations (TD 
9885) that were published in the Federal Register on Friday, December 
6, 2019. The final regulations implementing the base erosion and anti-
abuse tax, designed to prevent the reduction of tax liability by 
certain large corporate taxpayers through certain payments made to 
foreign related parties and certain tax credits.

DATES: 
    Effective date: The final regulations are effective on August 14, 
2020.
    Applicability date: December 6, 2019.

FOR FURTHER INFORMATION CONTACT: Sarah Hoyt at (202) 317-6848 or Julie 
Wang at (202) 317-6975 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    The final regulations (TD 9885) that are the subject of this 
correction are issued under Sec.  1.1.502-59A of the Internal Revenue 
Code.

Need for Correction

    As published, December 6, 2019 (84 FR 66968) the final regulations 
(TD 9885; FR DOC. 2019-25744) contains an error that needs 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.  1.1.502-59A   [Transferred]

0
Par. 2. Section 1.1502-59A is amended by transferring the section 
underneath the undesignated heading ``Special Taxes and Taxpayers'' and 
following Sec.  1.1502-55.
* * * * *

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2020-16383 Filed 8-13-20; 8:45 am]
BILLING CODE 4830-01-P