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]
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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withdrawn on October 21, 2022.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:
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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.
-----------------------------------------------------------------------
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