Recognition and Deferral of Section 987 Gain or Loss; Comment Period Reopening, 77921-77922 [2023-24650]
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Federal Register / Vol. 88, No. 218 / Tuesday, November 14, 2023 / Proposed Rules
(f) Compliance
Comply with this AD within the
compliance times specified, unless already
done.
(g) Required Actions
(1) Except as specified in paragraph (h) of
this AD: Perform all required actions within
the compliance times specified in, and in
accordance with, European Union Aviation
Safety Agency (EASA) AD 2023–0020, dated
January 23, 2023 (EASA AD 2023–0020).
(2) The action required by paragraph (g)(1)
of this AD may be performed by the owner/
operator (pilot) holding at least a private pilot
certificate and must be entered into the
aircraft records showing compliance with
this AD in accordance with 14 CFR 43.9(a)
and 91.417(a)(2)(v). The record must be
maintained as required by 14 CFR 91.417,
121.380, or 135.439.
khammond on DSKJM1Z7X2PROD with PROPOSALS
(h) Exceptions to EASA AD 2023–0020
(1) Where EASA AD 2023–0020 defines the
AMP as ‘‘The Aircraft Maintenance
Programme (AMP) contains the tasks on the
basis of which the scheduled maintenance is
conducted to ensure the continuing
airworthiness of each operated engine,’’
replace that text with ‘‘the aircraft
maintenance program containing the tasks on
the basis of which the scheduled
maintenance is conducted to ensure the
continuing airworthiness of each operated
airplane.’’
(2) Where EASA AD 2023–0020 specifies
the ALS as ‘‘The Airworthiness Limitations
Section of the GEAC Engine Maintenance
Manual (EMM) No. 0982309 Revision 21,’’
replace that text with ‘‘The Airworthiness
Limitations Section of the GEAC Engine
Maintenance Manual (EMM) No. 0982309
Revision 22.’’ The ALS in Revision 22 of the
EMM is unchanged from Revision 21.
(3) Where EASA AD 2023–0020 refers to its
effective date, this AD requires using the
effective date of this AD.
(4) Where paragraph (3) of EASA AD 2023–
0020 specifies ‘‘Within 12 months after the
effective date of this AD, revise the approved
AMP,’’ replace that text with ‘‘Within 90
days after the effective date of this AD, revise
the ALS of the existing approved engine
maintenance or inspection program, as
applicable.’’
(5) This AD does not require compliance
with paragraphs (1), (2), (4), and (5) of EASA
AD 2023–0020.
(6) This AD does not adopt the Remarks
paragraph of EASA AD 2023–0020.
(i) Provisions for Alternative Actions and
Intervals
After performing the actions required by
paragraph (g) of this AD, no alternative
actions and associated thresholds and
intervals, including life limits, are allowed
unless they are approved as specified in the
provisions of the ‘‘Ref. Publications’’ section
of EASA AD 2023–0020.
(j) Terminating Action for Certain Actions
Required by Affected ADs
(1) Accomplishing the actions required by
paragraph (g) of this AD terminates the
requirements of paragraphs (g)(1) through (3)
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of AD 2021–13–07 for model M601D–11,
M601E–11, M601E–11A, M601E–11AS,
M601E–11S, and M601F engines only.
(2) Accomplishing the actions required by
paragraph (g) of this AD terminates the
requirements of paragraphs (g)(1) through (3)
of AD 2023–01–10 for model M601E–11,
M601E–11A, M601E–11AS, M601E–11S, and
M601F engines only.
DEPARTMENT OF THE TREASURY
(k) Alternative Methods of Compliance
(AMOCs)
Recognition and Deferral of Section
987 Gain or Loss; Comment Period
Reopening
(1) The Manager, International Validation
Branch, FAA, has the authority to approve
AMOCs for this AD, if requested using the
procedures found in 14 CFR 39.19. In
accordance with 14 CFR 39.19, send your
request to your principal inspector or local
Flight Standards District Office, as
appropriate. If sending information directly
to the manager of the International Validation
Branch, send it to the attention of the person
identified in paragraph (l) of this AD and
email to ANE-AD-AMOC@faa.gov.
(2) Before using any approved AMOC,
notify your appropriate principal inspector,
or lacking a principal inspector, the manager
of the local flight standards district office/
certificate holding district office.
(l) Additional Information
For more information about this AD,
contact Barbara Caufield, Aviation Safety
Engineer, FAA, 1600 Stewart Avenue, Suite
410, Westbury, NY 11590; phone: (781) 238–
7146; email: barbara.caufield@faa.gov.
(m) Material Incorporated by Reference
(1) The Director of the Federal Register
approved the incorporation by reference
(IBR) of the service information listed in this
paragraph under 5 U.S.C. 552(a) and 1 CFR
part 51.
(2) You must use this service information
as applicable to do the actions required by
this AD, unless the AD specifies otherwise.
(i) European Union Aviation Safety Agency
(EASA) AD 2023–0020, dated January 23,
2023.
(ii) [Reserved]
(3) For EASA AD 2023–0020, contact
EASA, Konrad-Adenauer-Ufer 3, 50668
Cologne, Germany; phone: +49 221 8999 000;
email: ADs@easa.europa.eu; website:
easa.europa.eu. You may find this EASA AD
on the EASA website at ad.easa.europa.eu.
(4) You may view this service information
at FAA, Airworthiness Products Section,
Operational Safety Branch, 1200 District
Avenue, Burlington, MA 01803. For
information on the availability of this
material at the FAA, call (817) 222–5110.
(5) You may view this material at the
National Archives and Records
Administration (NARA). For information on
the availability of this material at NARA,
visit www.archives.gov/federal-register/cfr/
ibr-locations or email fr.inspection@nara.gov.
Issued on November 2, 2023.
Victor Wicklund,
Deputy Director, Compliance & Airworthiness
Division, Aircraft Certification Service.
[FR Doc. 2023–24639 Filed 11–13–23; 8:45 am]
BILLING CODE 4910–13–P
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Internal Revenue Service
26 CFR Part 1
[REG–128276–12]
RIN 1545–BO07
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking;
reopening of comment period.
AGENCY:
The Department of the
Treasury and the IRS are reopening the
comment period for REG–128276–12,
published in the Federal Register on
December 8, 2016, relating to the
determination and recognition of
taxable income or loss and foreign
currency gain or loss with respect to a
qualified business unit.
DATES: The comment period for REG–
128276–12 (81 FR 88882, December 8,
2016) (the ‘‘2016 proposed regulations’’)
is reopened, and additional written or
electronic comments and requests for a
public hearing must be received by
February 12, 2024.
ADDRESSES: Commenters are strongly
encouraged to submit additional public
comments electronically via the Federal
eRulemaking Portal at https://
www.regulations.gov (indicate IRS and
REG–128276–12) by following the
online instructions for submitting
comments. Requests for a public hearing
must be submitted as prescribed in the
‘‘Comments and Requests for a Public
Hearing’’ section. Once submitted to the
Federal eRulemaking Portal, comments
cannot be edited or withdrawn. The
Department of the Treasury (the
‘‘Treasury Department’’) and the IRS
will publish for public availability any
comments submitted to the IRS’s public
docket. Send paper submissions to:
CC:PA:01:PR (REG–128276–12), Room
5203, Internal Revenue Service, P.O.
Box 7604, Ben Franklin Station,
Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Jack
Zhou at (202) 317–6938; concerning
submissions of comments, requests for a
public hearing, or access to a public
hearing, Vivian Hayes at (202) 317–6901
(not toll-free numbers) or by email to
publichearings@irs.gov (preferred).
SUPPLEMENTARY INFORMATION: On
December 8, 2016, the Treasury
Department and the IRS published a
notice of proposed rulemaking (REG–
128276–12, 81 FR 88882, December 8,
SUMMARY:
E:\FR\FM\14NOP1.SGM
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77922
Federal Register / Vol. 88, No. 218 / Tuesday, November 14, 2023 / Proposed Rules
2016) (the ‘‘2016 proposed regulations’’)
in the Federal Register. The 2016
proposed regulations cross-reference
temporary regulations in Treasury
Decision 9795 (81 FR 88854, December
8, 2016) (the ‘‘temporary regulations’’),
which provided rules under section 987
of the Internal Revenue Code relating to
the determination and recognition of
taxable income or loss and foreign
currency gain or loss with respect to a
qualified business unit. On May 13,
2019, the Treasury Department and the
IRS published Treasury Decision 9857
(84 FR 20790, May 13, 2019), which
finalized parts of the 2016 proposed
regulations and withdrew one section of
the temporary regulations. The
temporary regulations that were not
finalized or withdrawn expired on
December 6, 2019. A notice of proposed
rulemaking published in this issue of
the Federal Register contains new
proposed regulations under section 987
and withdraws parts of the 2016
proposed regulations. The parts of the
2016 proposed regulations that remain
outstanding include: (1) rules regarding
the treatment of section 988 transactions
of a section 987 QBU (see §§ 1.987–1,
1.987–3, and 1.988–1 of the 2016
proposed regulations); (2) rules
regarding QBUs with the U.S. dollar as
their functional currency (see §§ 1.987–
1 and 1.987–6 of the 2016 proposed
regulations); (3) rules regarding the
translation of income used to pay
creditable foreign income taxes (see
§ 1.987–3 of the 2016 proposed
regulations); and (4) rules requiring the
deferral of certain section 988 loss that
arises with respect to related-party loans
(see § 1.988–2 of the 2016 proposed
regulations).
The Treasury Department and the IRS
are considering finalizing these parts of
the 2016 proposed regulations and,
therefore, are reopening the comment
period for 90 days. Comments that were
previously submitted in accordance
with the 2016 proposed regulations will
be considered and do not need to be
resubmitted.
Comments and Requests for a Public
Hearing: Before the parts of the 2016
proposed regulations that remain
outstanding are adopted as final
regulations, consideration will be given
to comments that are submitted timely
to the IRS as prescribed in this Notice
in the ‘‘Addresses’’ section. Any
comments submitted will be made
available at https://www.regulations.gov
or upon request.
A public hearing will be scheduled if
requested in writing by any person who
timely submits written comments.
Requests for a public hearing are also
encouraged to be made electronically. If
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16:09 Nov 13, 2023
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Internal Revenue Service
copy. Send paper submissions to:
CC:PA:01:PR (REG–142338–07), Room
5203, Internal Revenue Service, P.O.
Box 7604, Ben Franklin Station,
Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations,
Ward L. Thomas at (202) 317–5800 (not
a toll-free number); concerning
submission of comments and requests
for a public hearing, contact Vivian
Hayes by email at publichearings@
irs.gov (preferred) or by phone at (202)
317–6901 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
26 CFR Part 53
Background
a public hearing is scheduled, notice of
the date and time for the public hearing
will be published in the Federal
Register.
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations
Section, Associate Chief Counsel, (Procedure
and Administration).
[FR Doc. 2023–24650 Filed 11–9–23; 4:15 pm]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
[REG–142338–07]
RIN 1545–BI33
Taxes on Taxable Distributions From
Donor Advised Funds Under Section
4966
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking.
AGENCY:
This document contains
proposed regulations regarding excise
taxes on taxable distributions made by
a sponsoring organization from a donor
advised fund (DAF), and on the
agreement of certain fund managers to
the making of such distributions. The
proposed regulations would provide
guidance regarding DAFs and taxable
distributions. The proposed regulations
generally would apply to certain
organizations, including community
foundations and other charitable
organizations, that maintain one or more
DAFs, and to other persons involved
with the DAFs, including donors,
donor-advisors, related persons, and
certain fund managers.
DATES: Written or electronic comments
and requests for a public hearing must
be received by January 16, 2024.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic
submissions via the Federal
eRulemaking Portal at https://
www.regulations.gov (indicate IRS and
REG–142338–07) by following the
online instructions for submitting
comments. Requests for a public hearing
must be submitted as prescribed in the
‘‘Comments and Requests for a Public
Hearing’’ section. Once submitted to the
Federal eRulemaking Portal, comments
cannot be edited or withdrawn. The
Department of the Treasury (Treasury
Department) and the IRS will publish
for public availability any comment
received to its public docket, whether
submitted electronically or in hard
SUMMARY:
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I. Overview
Some charitable organizations
(including community foundations)
establish accounts to which donors may
contribute and thereafter provide
nonbinding advice or recommendations
with regard to distributions from the
account or the investment of assets in
the account. Such accounts are
commonly referred to as ‘‘donor advised
funds’’ or ‘‘DAFs.’’ Sections 1231–1235
of the Pension Protection Act of 2006
(PPA), Public Law 109–280, 120 Stat.
780, 1094–1102 (August 17, 2006),
enacted various amendments to the
Internal Revenue Code (Code) regarding
DAFs. Among these, section 1232 of the
PPA amended section 4958 of the Code
to add special rules relating to excess
benefit transactions with DAFs; section
1231(b) of the PPA added section 4967
to the Code, which imposes an excise
tax on prohibited benefits resulting from
distributions from DAFs; and section
1231(a) of the PPA added section 4966
of the Code, which imposes excise taxes
on taxable distributions made by
sponsoring organizations from a DAF,
and on the agreement of certain fund
managers to the making of such
distributions. This notice of proposed
rulemaking contains proposed
amendments to 26 CFR part 53
(Foundation and Similar Excise Taxes)
under section 4966 (proposed
regulations).
II. Statutory Provisions
A. Section 4958
Section 4958 imposes an excise tax on
any ‘‘excess benefit transaction,’’ which
is defined generally under section
4958(c)(1) as any transaction in which
an economic benefit is provided, the
value of which exceeds the value of any
consideration received, by an applicable
tax-exempt organization (including a
section 501(c)(3) sponsoring
organization of a DAF) directly or
indirectly to or for the use of a
disqualified person with respect to a
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]]>Agencies
[Federal Register Volume 88, Number 218 (Tuesday, November 14, 2023)]
[Proposed Rules]
[Pages 77921-77922]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-24650]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-128276-12]
RIN 1545-BO07
Recognition and Deferral of Section 987 Gain or Loss; Comment
Period Reopening
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; reopening of comment period.
-----------------------------------------------------------------------
SUMMARY: The Department of the Treasury and the IRS are reopening the
comment period for REG-128276-12, published in the Federal Register on
December 8, 2016, relating to the determination and recognition of
taxable income or loss and foreign currency gain or loss with respect
to a qualified business unit.
DATES: The comment period for REG-128276-12 (81 FR 88882, December 8,
2016) (the ``2016 proposed regulations'') is reopened, and additional
written or electronic comments and requests for a public hearing must
be received by February 12, 2024.
ADDRESSES: Commenters are strongly encouraged to submit additional
public comments electronically via the Federal eRulemaking Portal at
https://www.regulations.gov (indicate IRS and REG-128276-12) by
following the online instructions for submitting comments. Requests for
a public hearing must be submitted as prescribed in the ``Comments and
Requests for a Public Hearing'' section. Once submitted to the Federal
eRulemaking Portal, comments cannot be edited or withdrawn. The
Department of the Treasury (the ``Treasury Department'') and the IRS
will publish for public availability any comments submitted to the
IRS's public docket. Send paper submissions to: CC:PA:01:PR (REG-
128276-12), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben
Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Jack Zhou at (202) 317-6938;
concerning submissions of comments, requests for a public hearing, or
access to a public hearing, Vivian Hayes at (202) 317-6901 (not toll-
free numbers) or by email to [email protected] (preferred).
SUPPLEMENTARY INFORMATION: On December 8, 2016, the Treasury Department
and the IRS published a notice of proposed rulemaking (REG-128276-12,
81 FR 88882, December 8,
[[Page 77922]]
2016) (the ``2016 proposed regulations'') in the Federal Register. The
2016 proposed regulations cross-reference temporary regulations in
Treasury Decision 9795 (81 FR 88854, December 8, 2016) (the ``temporary
regulations''), which provided rules under section 987 of the Internal
Revenue Code relating to the determination and recognition of taxable
income or loss and foreign currency gain or loss with respect to a
qualified business unit. On May 13, 2019, the Treasury Department and
the IRS published Treasury Decision 9857 (84 FR 20790, May 13, 2019),
which finalized parts of the 2016 proposed regulations and withdrew one
section of the temporary regulations. The temporary regulations that
were not finalized or withdrawn expired on December 6, 2019. A notice
of proposed rulemaking published in this issue of the Federal Register
contains new proposed regulations under section 987 and withdraws parts
of the 2016 proposed regulations. The parts of the 2016 proposed
regulations that remain outstanding include: (1) rules regarding the
treatment of section 988 transactions of a section 987 QBU (see
Sec. Sec. 1.987-1, 1.987-3, and 1.988-1 of the 2016 proposed
regulations); (2) rules regarding QBUs with the U.S. dollar as their
functional currency (see Sec. Sec. 1.987-1 and 1.987-6 of the 2016
proposed regulations); (3) rules regarding the translation of income
used to pay creditable foreign income taxes (see Sec. 1.987-3 of the
2016 proposed regulations); and (4) rules requiring the deferral of
certain section 988 loss that arises with respect to related-party
loans (see Sec. 1.988-2 of the 2016 proposed regulations).
The Treasury Department and the IRS are considering finalizing
these parts of the 2016 proposed regulations and, therefore, are
reopening the comment period for 90 days. Comments that were previously
submitted in accordance with the 2016 proposed regulations will be
considered and do not need to be resubmitted.
Comments and Requests for a Public Hearing: Before the parts of the
2016 proposed regulations that remain outstanding are adopted as final
regulations, consideration will be given to comments that are submitted
timely to the IRS as prescribed in this Notice in the ``Addresses''
section. Any comments submitted will be made available at https://www.regulations.gov or upon request.
A public hearing will be scheduled if requested in writing by any
person who timely submits written comments. Requests for a public
hearing are also encouraged to be made electronically. If a public
hearing is scheduled, notice of the date and time for the public
hearing will be published in the Federal Register.
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations Section, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2023-24650 Filed 11-9-23; 4:15 pm]
BILLING CODE 4830-01-P
