Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax; Correcting Amendment, 64040 [2020-20419]
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Federal Register / Vol. 85, No. 197 / Friday, October 9, 2020 / Rules and Regulations
consideration in money or money’s
worth.
(B) Example. The following example
illustrates the application of this
paragraph (c)(2)(v):
Example. Employer T operates a
restaurant. T provides food and
beverages to its food service employees
before, during, and after their shifts for
no consideration. Under section
274(e)(8) and this paragraph (c)(2)(v),
the expenses associated with the food
and beverages provided to the
employees are not subject to the 50
percent deduction limitation in
paragraph (a) of this section because the
restaurant sells food and beverages to
customers in a bona fide transaction for
an adequate and full consideration in
money or money’s worth. Thus, T may
deduct 100 percent of the food and
beverage expenses.
(d) Applicability date. This section
applies for taxable years that begin on
or after October 9, 2020.
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9902) that
are the subject of this correction are
issued under section 951A of the Code.
Need for Correction
As published, the final regulations
(TD 9902) contain 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
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
■
Authority: 26 U.S.C. 7805 * * *
Sunita Lough,
Deputy Commissioner for Services and
Enforcement.
Approved: September 25, 2020.
David J. Kautter,
Assistant Secretary of the Treasury (Tax
Policy).
Par. 2. Section 1.951A–2 is amended
by adding a sentence at the end of
paragraph (c)(7)(viii)(E)(2)(ii) to read as
follows:
■
§ 1.951A–2
Tested Income and tested loss.
*
[FR Doc. 2020–21990 Filed 10–2–20; 4:15 pm]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9902]
RIN 1545–BP15
Guidance Under Sections 951A and
954 Regarding Income Subject to a
High Rate of Foreign Tax; Correcting
Amendment
Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendments.
AGENCY:
This document contains
corrections to Treasury Decision 9902,
which was published in the Federal
Register on Thursday, July 23, 2020.
Treasury Decision 9902 contained final
regulations under the global intangible
low-taxed income and subpart F income
provisions of the Internal Revenue Code
regarding the treatment of income that
is subject to a high rate of foreign tax.
DATES: This correction is effective on
October 9, 2020.
FOR FURTHER INFORMATION CONTACT:
Jorge M. Oben or Larry R. Pounders at
(202) 317–6934 (not a toll-free number).
*
*
*
*
(c) * * *
(7) * * *
(viii) * * *
(E) * * *
(2) * * *
(ii) * * * Notwithstanding the rule
set forth in this paragraph
(c)(7)(viii)(E)(2)(ii), a controlled foreign
corporation is not a member of a CFC
group if, as of the close of its CFC
inclusion year, the controlled foreign
corporation does not have a controlling
domestic shareholder.
Crystal Pemberton,
Senior Federal Register Liaison, Publications
and Regulations Branch, Legal Processing
Division, Associate Chief Counsel (Procedure
and Administration).
[FR Doc. 2020–20419 Filed 10–8–20; 8:45 am]
BILLING CODE 4830–01–P
SUMMARY:
VerDate Sep<11>2014
16:35 Oct 08, 2020
Jkt 253001
DEPARTMENT OF VETERANS
AFFAIRS
38 CFR Part 1
RIN 2900–AQ64
Disclosure of Certain Protected
Records Without Written Consent
Department of Veterans Affairs.
Final rule.
AGENCY:
ACTION:
The Department of Veterans
Affairs (VA) adopts as final with no
SUMMARY:
PO 00000
Frm 00048
Fmt 4700
Sfmt 4700
changes, a proposed rule amending its
regulations on disclosure of certain
records. Recent changes in law, to
include the VA MISSION Act of 2018,
now authorize VA to disclose certain
protected records to non-VA entities for
purposes of providing health care or
performing other health care-related
activities or functions to include
recovering or collecting reasonable
charges for care furnished.
DATES: The final rule is effective
November 9, 2020.
FOR FURTHER INFORMATION CONTACT:
Stephania H. Griffin, Director,
Information Access and Privacy Office
(10A7), Department of Veterans Affairs,
810 Vermont Avenue NW, Washington,
DC 20420; (704) 245–2492. (This is not
a toll-free number.)
SUPPLEMENTARY INFORMATION: In
accordance with section 5701 of title 38
United States Code (U.S.C.), records and
files maintained by VA on veterans and
beneficiaries, including medical
records, are generally confidential, and
VA may not disclose or release these
materials except as provided by law.
Moreover, records of the identity,
diagnosis, prognosis, or treatment by or
for VA of any patient related to drug
abuse, alcoholism or alcohol abuse,
infection with the human
immunodeficiency virus (HIV), or sickle
cell anemia as prescribed by 38 U.S.C.
7332(a)(1) are confidential and subject
to special protection against disclosure.
These records may only be disclosed for
the specific purposes and under the
circumstances expressly authorized
under 38 U.S.C. 7332(b), where section
(b)(1) authorizes disclosure with the
prior written consent of the patient to
the extent, circumstances, and purposes
allowed by VA regulations, and section
(b)(2) authorizes disclosure under
certain circumstances with or without
the written consent of the patient.
Section 3 of Public Law (Pub. L.) 115–
26 (April 19, 2017) amended 38 U.S.C.
7332 by adding a new paragraph
(b)(2)(H), authorizing disclosure of
7332-protected records without the
written consent of the patient or subject
of the record to a non-VA entity
(including private entities and other
Federal agencies) that provides VAauthorized hospital care or medical
services to veterans. It also provided
that any non-VA entity receiving such
records may not redisclose or use those
record for a purpose other than that for
which the disclosure was made.
Subsequently, section 132 of Public
Law 115–182, the John S. McCain III,
Daniel K. Akaka, and Samuel R. Johnson
VA Maintaining Internal Systems and
Strengthening Integrated Outside
E:\FR\FM\09OCR1.SGM
09OCR1
]]>Agencies
[Federal Register Volume 85, Number 197 (Friday, October 9, 2020)]
[Rules and Regulations]
[Page 64040]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-20419]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9902]
RIN 1545-BP15
Guidance Under Sections 951A and 954 Regarding Income Subject to
a High Rate of Foreign Tax; Correcting Amendment
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Correcting amendments.
-----------------------------------------------------------------------
SUMMARY: This document contains corrections to Treasury Decision 9902,
which was published in the Federal Register on Thursday, July 23, 2020.
Treasury Decision 9902 contained final regulations under the global
intangible low-taxed income and subpart F income provisions of the
Internal Revenue Code regarding the treatment of income that is subject
to a high rate of foreign tax.
DATES: This correction is effective on October 9, 2020.
FOR FURTHER INFORMATION CONTACT: Jorge M. Oben or Larry R. Pounders at
(202) 317-6934 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9902) that are the subject of this
correction are issued under section 951A of the Code.
Need for Correction
As published, the final regulations (TD 9902) contain 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 1.951A-2 is amended by adding a sentence at the end of
paragraph (c)(7)(viii)(E)(2)(ii) to read as follows:
Sec. 1.951A-2 Tested Income and tested loss.
* * * * *
(c) * * *
(7) * * *
(viii) * * *
(E) * * *
(2) * * *
(ii) * * * Notwithstanding the rule set forth in this paragraph
(c)(7)(viii)(E)(2)(ii), a controlled foreign corporation is not a
member of a CFC group if, as of the close of its CFC inclusion year,
the controlled foreign corporation does not have a controlling domestic
shareholder.
Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch,
Legal Processing Division, Associate Chief Counsel (Procedure and
Administration).
[FR Doc. 2020-20419 Filed 10-8-20; 8:45 am]
BILLING CODE 4830-01-P
