Guidance Related to the Foreign Tax Credit; Hearing, 7903 [2023-02574]
Download as PDF
Federal Register / Vol. 88, No. 25 / Tuesday, February 7, 2023 / Proposed Rules
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–112096–22]
RIN 1545–BQ46
Guidance Related to the Foreign Tax
Credit; Hearing
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking;
notice of hearing.
AGENCY:
This document provides a
notice of public hearing on proposed
regulations relating to the foreign tax
credit, including guidance with respect
to the reattribution asset rule for
purposes of allocating and apportioning
foreign taxes, the cost recovery
requirement, and the attribution rule for
withholding tax on royalty payments.
DATES: The public hearing is being held
on Wednesday, February 15, 2023, at 10
a.m. EDT. The IRS must receive
speakers’ outlines of the topics to be
discussed at the public hearing by
Friday, February 10, 2023.
ADDRESSES: The public hearing is being
held by teleconference. Individuals that
have submitted an outline of testimony
and want to testify (by telephone) at the
public hearing must send an email to
publichearings@irs.gov to receive the
telephone number and access code for
the hearing. The subject line of the
email must contain the regulation
number [REG–112096–22] and the word
TESTIFY. For example, the subject line
may say: Request to TESTIFY at Hearing
for REG–112096–22. The email must
include the name(s) of the speaker(s)
and title(s) only. No outlines will be
accepted by email. Send outline
submissions electronically via the
Federal eRulemaking Portal at
www.regulations.gov (IRS REG–112096–
22). The email must be received by
February 10, 2023.
FOR FURTHER INFORMATION CONTACT:
Concerning §§ 1.901–2 and 1.903–1,
Teisha Ruggiero, (646) 259–8116,
§ 1.861–20, Suzanne Walsh, (202) 317–
4908; concerning submissions of
comments, the hearing, and the access
code to attend the hearing by
teleconferencing, Vivian Hayes at (202)
317–5306 (not toll-free numbers) or
publichearings@irs.gov. If emailing,
please include Attend, Testify, or
Agenda Request and [REG–112096–22]
in the email subject line.
SUPPLEMENTARY INFORMATION: The
subject of the public hearing is the
ddrumheller on DSK120RN23PROD with PROPOSALS
SUMMARY:
VerDate Sep<11>2014
18:27 Feb 06, 2023
Jkt 259001
notice of proposed rulemaking REG–
112096–22 that was published in the
Federal Register on Tuesday, November
22, 2022, 87 FR 71271.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing. Persons who wish
to present oral comments telephonically
at the hearing that previously submitted
written comments by January 23, 2023,
must submit an outline on the topics to
be addressed and the amount of time to
be devoted to each topic by February 10,
2023. A period of 10 minutes is allotted
to each person for presenting oral
comments.
After receiving outlines, the IRS will
prepare an agenda containing the
schedule of speakers. The agenda will
be available via Federal eRulemaking
Portal (www.Regulations.gov) under the
title of Supporting & Related Material by
February 12, 2023. The public hearing
agenda will contain the telephone
number and access code.
Individuals who want to attend (by
telephone) the public hearing must also
send an email to publichearings@irs.gov
to receive the telephone number and
access code for the hearing. The subject
line of the email must contain the
regulation number [REG–112096–22]
and the word ATTEND. For example,
the subject line may say: Request to
ATTEND Hearing for REG–112096–22.
The email requesting to attend the
public hearing must be received by 5
p.m. EDT two (2) business days before
the date that the hearing is scheduled.
The telephonic hearing will be made
accessible to people with disabilities. To
request special assistance during the
telephonic hearing please contact the
Publications and Regulations Branch of
the Office of Associate Chief Counsel
(Procedure and Administration) by
sending an email to publichearings@
irs.gov (preferred) or by telephone at
(202) 317–5306 (not a toll-free number)
by Friday, February 10, 2023.
Any questions regarding speaking at
or attending a public hearing may also
be emailed to publichearings@irs.gov.
Oluwafunmilayo A. Taylor,
Branch Chief, Publications and Regulations
Branch, Legal Processing Division, Associate
Chief Counsel (Procedure and
Administration).
[FR Doc. 2023–02574 Filed 2–6–23; 8:45 am]
BILLING CODE 4830–01–P
PO 00000
Frm 00013
Fmt 4702
Sfmt 4702
7903
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
[EPA–R04–OAR–2021–0769; FRL–10576–
01–R4]
Air Plan Approval; NC; Transportation
Conformity
Environmental Protection
Agency (EPA).
ACTION: Proposed rule.
AGENCY:
The Environmental Protection
Agency (EPA) is proposing to approve
State Implementation Plan (SIP)
revisions submitted by the State of
North Carolina, through the North
Carolina Department of Environmental
Quality (DEQ), Division of Air Quality
(DAQ) on September 24, 2021. The SIP
revisions replace previously approved
memoranda of agreement (MOAs) with
thirteen updated MOAs outlining
transportation conformity criteria and
procedures related to interagency
consultation, conflict resolution, public
participation, and enforceability of
certain transportation-related control
and mitigation measures. EPA is
proposing to determine that North
Carolina’s September 24, 2021, SIP
revisions are consistent with the
applicable provisions of the Clean Air
Act (CAA or Act).
DATES: Written comments must be
received on or before March 9, 2023.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–R04–
OAR–2021–0769 at https://
www.regulations.gov. Follow the online
instructions for submitting comments.
Once submitted, comments cannot be
edited or removed from Regulations.gov.
EPA may publish any comment received
to its public docket. Do not submit
electronically any information you
consider to be Confidential Business
Information (CBI) or other information
whose disclosure is restricted by statute.
Multimedia submissions (audio, video,
etc.) must be accompanied by a written
comment. The written comment is
considered the official comment and
should include discussion of all points
you wish to make. EPA will generally
not consider comments or comment
contents located outside of the primary
submission (i.e., on the web, cloud, or
other file sharing system). For
additional submission methods, the full
EPA public comment policy,
information about CBI or multimedia
submissions, and general guidance on
making effective comments, please visit
https://www2.epa.gov/dockets/
commenting-epa-dockets.
SUMMARY:
E:\FR\FM\07FEP1.SGM
07FEP1
Agencies
[Federal Register Volume 88, Number 25 (Tuesday, February 7, 2023)]
[Proposed Rules]
[Page 7903]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-02574]
[[Page 7903]]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-112096-22]
RIN 1545-BQ46
Guidance Related to the Foreign Tax Credit; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; notice of hearing.
-----------------------------------------------------------------------
SUMMARY: This document provides a notice of public hearing on proposed
regulations relating to the foreign tax credit, including guidance with
respect to the reattribution asset rule for purposes of allocating and
apportioning foreign taxes, the cost recovery requirement, and the
attribution rule for withholding tax on royalty payments.
DATES: The public hearing is being held on Wednesday, February 15,
2023, at 10 a.m. EDT. The IRS must receive speakers' outlines of the
topics to be discussed at the public hearing by Friday, February 10,
2023.
ADDRESSES: The public hearing is being held by teleconference.
Individuals that have submitted an outline of testimony and want to
testify (by telephone) at the public hearing must send an email to
[email protected] to receive the telephone number and access code
for the hearing. The subject line of the email must contain the
regulation number [REG-112096-22] and the word TESTIFY. For example,
the subject line may say: Request to TESTIFY at Hearing for REG-112096-
22. The email must include the name(s) of the speaker(s) and title(s)
only. No outlines will be accepted by email. Send outline submissions
electronically via the Federal eRulemaking Portal at
www.regulations.gov (IRS REG-112096-22). The email must be received by
February 10, 2023.
FOR FURTHER INFORMATION CONTACT: Concerning Sec. Sec. 1.901-2 and
1.903-1, Teisha Ruggiero, (646) 259-8116, Sec. 1.861-20, Suzanne
Walsh, (202) 317-4908; concerning submissions of comments, the hearing,
and the access code to attend the hearing by teleconferencing, Vivian
Hayes at (202) 317-5306 (not toll-free numbers) or
[email protected]. If emailing, please include Attend, Testify, or
Agenda Request and [REG-112096-22] in the email subject line.
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking REG-112096-22 that was published in the
Federal Register on Tuesday, November 22, 2022, 87 FR 71271.
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments telephonically at the hearing that
previously submitted written comments by January 23, 2023, must submit
an outline on the topics to be addressed and the amount of time to be
devoted to each topic by February 10, 2023. A period of 10 minutes is
allotted to each person for presenting oral comments.
After receiving outlines, the IRS will prepare an agenda containing
the schedule of speakers. The agenda will be available via Federal
eRulemaking Portal (www.Regulations.gov) under the title of Supporting
& Related Material by February 12, 2023. The public hearing agenda will
contain the telephone number and access code.
Individuals who want to attend (by telephone) the public hearing
must also send an email to [email protected] to receive the
telephone number and access code for the hearing. The subject line of
the email must contain the regulation number [REG-112096-22] and the
word ATTEND. For example, the subject line may say: Request to ATTEND
Hearing for REG-112096-22. The email requesting to attend the public
hearing must be received by 5 p.m. EDT two (2) business days before the
date that the hearing is scheduled.
The telephonic hearing will be made accessible to people with
disabilities. To request special assistance during the telephonic
hearing please contact the Publications and Regulations Branch of the
Office of Associate Chief Counsel (Procedure and Administration) by
sending an email to [email protected] (preferred) or by telephone
at (202) 317-5306 (not a toll-free number) by Friday, February 10,
2023.
Any questions regarding speaking at or attending a public hearing
may also be emailed to [email protected].
Oluwafunmilayo A. Taylor,
Branch Chief, Publications and Regulations Branch, Legal Processing
Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2023-02574 Filed 2-6-23; 8:45 am]
BILLING CODE 4830-01-P