Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property, 63981 [2022-22891]

Download as PDF Federal Register / Vol. 87, No. 203 / Friday, October 21, 2022 / Proposed Rules [REG–121509–00] Treasury Department and the IRS continue to develop the new proposed regulations. The IRS may, where appropriate, challenge taxpayer positions giving rise to inappropriate results. RIN 1545–AY54 List of Subjects in 26 CFR Part 1 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property Internal Revenue Service (IRS), Treasury. ACTION: Withdrawal of notice of proposed rulemaking. AGENCY: This document withdraws a notice of proposed rulemaking published in the Federal Register on August 29, 2006. The notice of proposed rulemaking relates to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Internal Revenue Code (the ‘‘Code’’) and related basis adjustments under section 961 of the Code. DATES: The proposed regulations are withdrawn on October 21, 2022. FOR FURTHER INFORMATION CONTACT: Joshua P. Roffenbender, (202) 317–6934, or Chadwick Rowland, (202) 317–6937 (not toll-free numbers). SUPPLEMENTARY INFORMATION: jspears on DSK121TN23PROD with PROPOSALS SUMMARY: Background On August 29, 2006, the Treasury Department and the IRS issued a notice of proposed rulemaking relating to the exclusion from gross income of previously taxed earnings and profits under section 959 and related basis adjustments under section 961 (71 FR 51155), corrections to which were published in the Federal Register on December 8, 2006 (71 FR 71116) (together, the ‘‘2006 proposed regulations’’). On December 14, 2018, the Treasury Department and the IRS issued Notice 2019–01 (2019–02 I.R.B. 275), which announced an intent to withdraw the 2006 proposed regulations and issue a new notice of proposed rulemaking under sections 959 and 961 (the ‘‘new proposed regulations’’). This document withdraws the 2006 proposed regulations. Those proposed regulations were never finalized, never went into effect, and did not indicate that taxpayers could rely on them. Withdrawing the proposed regulations at this point will help prevent possible abuse or other misuse of them—such as inappropriate basis adjustments in certain stock acquisitions to which section 304(a)(1) applies—while the VerDate Sep<11>2014 16:38 Oct 20, 2022 Jkt 259001 Income taxes, Reporting and recordkeeping requirements. Withdrawal of a Notice of Proposed Rulemaking Accordingly, under the authority of 26 U.S.C. 7805, the notice of proposed rulemaking (REG–121509–00) published in the Federal Register on August 29, 2006 (71 FR 51155), corrections to which were published in the Federal Register on December 8, 2006 (71 FR 71116), is withdrawn. ■ Douglas W. O’Donnell, Deputy Commissioner for Services and Enforcement. [FR Doc. 2022–22891 Filed 10–20–22; 8:45 am] BILLING CODE 4830–01–P DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG–2022–0806] RIN 1625–AA00 Safety Zones in Reentry Sites; Jacksonville, Daytona, Cape Canaveral, Tampa, and Tallahassee, Florida Coast Guard, DHS. Notice of proposed rulemaking. AGENCY: ACTION: This proposed rule would implement a special activities provision of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021. The Coast Guard is proposing to establish five temporary safety zones for the safe splashdown and recovery of reentry vehicles launched by Space Exploration Technologies Corporation (SpaceX) in support of National Aeronautics and Space Administration (NASA) and privately chartered missions. The proposed temporary safety zones are located within the Coast Guard District Seven area of responsibility (AOR) offshore of Jacksonville, Daytona, Cape Canaveral, Tampa, and Tallahassee, Florida. This proposed rule would prohibit U.S.-flagged vessels from entering any of the temporary safety zones unless authorized by the District SUMMARY: PO 00000 Frm 00014 Fmt 4702 Sfmt 4702 63981 Commander of the Seventh Coast Guard District, a Coast Guard Captain of the Port, or a designated representative. Foreign-flagged vessels would be encouraged to remain outside the safety zones. This action is necessary to protect vessels and waterway users from the potential hazards created by reentry vehicle splashdowns and recovery operations in the U.S. Exclusive Economic Zone (EEZ). It is also necessary to provide for the safe recovery of reentry vehicles, and any personnel involved in reentry services, after the splashdown. We invite your comments on this proposed rulemaking. DATES: Comments and related material must be received by the Coast Guard on or before November 21, 2022. ADDRESSES: You may submit comments identified by docket number USCG– 2022–0806 using the Federal Decision Making Portal at https:// www.regulations.gov. See the ‘‘Public Participation and Request for Comments’’ portion of the SUPPLEMENTARY INFORMATION section for further instructions on submitting comments. FOR FURTHER INFORMATION CONTACT: If you have questions about this proposed rulemaking, call or email Lieutenant Ryan Gilbert, District 7 Waterways Division (dpw), U.S. Coast Guard; telephone (305) 415–6748, email Ryan.A.Gilbert@uscg.mil. SUPPLEMENTARY INFORMATION: I. Table of Abbreviations AOR Area of Responsibility BNM Broadcast Notice to Mariners CFR Code of Federal Regulations COTP Captain of the Port DHS Department of Homeland Security EEZ Exclusive Economic Zone FAA Federal Aviation Administration FL Florida FR Federal Register MSIB Marine Safety Information Bulletin NASA National Aeronautics and Space Administration NM Nautical Mile NPRM Notice of Proposed Rulemaking § Section SpaceX Space Exploration Technologies Corporation U.S. United States U.S.C. United States Code II. Background, Purpose, and Legal Basis On January 1, 2021, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Pub. L. 116–283) (Authorization Act) was enacted. Section 8343 (134 Stat. 4710) calls for the Coast Guard to conduct a two-year pilot program to establish and implement a process to establish safety zones to address special E:\FR\FM\21OCP1.SGM 21OCP1

Agencies

[Federal Register Volume 87, Number 203 (Friday, October 21, 2022)]
[Proposed Rules]
[Page 63981]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-22891]



[[Page 63981]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-121509-00]
RIN 1545-AY54


Exclusion From Gross Income of Previously Taxed Earnings and 
Profits, and Adjustments to Basis of Stock in Controlled Foreign 
Corporations and of Other Property

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking.

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SUMMARY: This document withdraws a notice of proposed rulemaking 
published in the Federal Register on August 29, 2006. The notice of 
proposed rulemaking relates to the exclusion from gross income of 
previously taxed earnings and profits under section 959 of the Internal 
Revenue Code (the ``Code'') and related basis adjustments under section 
961 of the Code.

DATES: The proposed regulations are withdrawn on October 21, 2022.

FOR FURTHER INFORMATION CONTACT: Joshua P. Roffenbender, (202) 317-
6934, or Chadwick Rowland, (202) 317-6937 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    On August 29, 2006, the Treasury Department and the IRS issued a 
notice of proposed rulemaking relating to the exclusion from gross 
income of previously taxed earnings and profits under section 959 and 
related basis adjustments under section 961 (71 FR 51155), corrections 
to which were published in the Federal Register on December 8, 2006 (71 
FR 71116) (together, the ``2006 proposed regulations''). On December 
14, 2018, the Treasury Department and the IRS issued Notice 2019-01 
(2019-02 I.R.B. 275), which announced an intent to withdraw the 2006 
proposed regulations and issue a new notice of proposed rulemaking 
under sections 959 and 961 (the ``new proposed regulations'').
    This document withdraws the 2006 proposed regulations. Those 
proposed regulations were never finalized, never went into effect, and 
did not indicate that taxpayers could rely on them. Withdrawing the 
proposed regulations at this point will help prevent possible abuse or 
other misuse of them--such as inappropriate basis adjustments in 
certain stock acquisitions to which section 304(a)(1) applies--while 
the Treasury Department and the IRS continue to develop the new 
proposed regulations. The IRS may, where appropriate, challenge 
taxpayer positions giving rise to inappropriate results.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Withdrawal of a Notice of Proposed Rulemaking

0
Accordingly, under the authority of 26 U.S.C. 7805, the notice of 
proposed rulemaking (REG-121509-00) published in the Federal Register 
on August 29, 2006 (71 FR 51155), corrections to which were published 
in the Federal Register on December 8, 2006 (71 FR 71116), is 
withdrawn.

Douglas W. O'Donnell,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2022-22891 Filed 10-20-22; 8:45 am]
BILLING CODE 4830-01-P
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