Income and Currency Gain or Loss With Respect to a Qualified Business Unit; Correction, 84770 [2023-26785]
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84770
Federal Register / Vol. 88, No. 233 / Wednesday, December 6, 2023 / Proposed Rules
132422–17) at 88 FR 78134 (the
proposed regulations). The proposed
regulations that are the subject of this
correction are issued under sections
861, 985 through 989, and 1502 of the
Internal Revenue Code.
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–132422–17]
RIN 1545–BO07
Income and Currency Gain or Loss
With Respect to a Qualified Business
Unit; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking;
correction.
AGENCY:
This document contains a
correction to a notice of proposed
rulemaking that was published in the
Federal Register on Tuesday, November
14, 2023. The proposed regulations
provide guidance relating to the
determination of taxable income or loss
and foreign currency gain or loss with
respect to a qualified business unit.
DATES: Written or electronic comments
and requests for a public hearing are
still being accepted and must be
received by February 12, 2024.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically via the Federal
eRulemaking Portal at https://
www.regulations.gov (indicate IRS and
REG–132422–17) 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cannot be edited or withdrawn.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 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–132422–17), Room
5203, Internal Revenue Service, P.O.
Box 7604, Ben Franklin Station,
Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations,
Raphael J. Cohen at (202) 317–6938;
concerning submissions of comments,
requests for a public hearing, and access
to a public hearing, Vivian Hayes at
(202) 317–6901 (not toll-free numbers)
or by email to publichearings@irs.gov
(preferred).
lotter on DSK11XQN23PROD with PROPOSALS1
SUMMARY:
SUPPLEMENTARY INFORMATION:
Background
On November 14, 2023, the Federal
Register published a notice of proposed
rulemaking and partial withdrawal of
notice of proposed rulemaking (REG–
VerDate Sep<11>2014
16:09 Dec 05, 2023
Jkt 262001
Need for Correction
As published, the preamble to the
proposed regulations contains errors
that may prove to be misleading. This
document provides a technical
correction to the preamble, which
clarifies the misleading paragraph.
Correction of Publication
Accordingly, the publication of the
proposed regulations (REG–132422–17),
which was the subject of FR Doc. 2023–
24649, published on November 14,
2023, is corrected on page 78156, in the
third column, by revising the first full
paragraph to read, ‘‘Taxpayers may rely
on the proposed regulations (and so
much of the final regulations as would
not be modified by the proposed
regulations) for taxable years ending
after November 9, 2023, provided the
taxpayer and each member of its
consolidated group and section 987
electing group consistently follow the
proposed regulations in their entirety
and in a consistent manner.
Additionally, for taxable years ending
after November 9, 2023, and beginning
on or before December 31, 2024,
taxpayers may rely on only the
applicability date provisions in
proposed §§ 1.861–9(g)(2)(v), 1.985–5(g),
1.987–14(a), (c), and (d), 1.988–1(i),
1.988–4(b)(2)(ii), and 1.989(a)–1(b)(4)
and (d)(4), provided that: (1) the
taxpayer and each member of its
consolidated group and section 987
electing group consistently follow those
provisions in their entirety and in a
consistent manner for those taxable
years; (2) with respect to any
terminating QBU to which proposed
§ 1.987–14(a)(2) would apply or
partnership to which proposed § 1.987–
14(a)(3) would apply, the taxpayer and
each member of its consolidated group
and section 987 electing group
consistently follow all of the proposed
regulations (and so much of the final
regulations as would not be modified by
the proposed regulations) in their
entirety and in a consistent manner; and
(3) to the extent that, under proposed
§ 1.987–14(c), proposed § 1.987–10
would be applied in lieu of prior
§ 1.987–10, the taxpayer and each
member of its consolidated group and
section 987 electing group consistently
follow proposed § 1.987–10 in its
entirety and in a consistent manner.
Thus, for example, a calendar year
taxpayer that has consistently followed
PO 00000
Frm 00012
Fmt 4702
Sfmt 4702
the method described in the 1991
proposed regulations could continue to
follow that method for the 2024 taxable
year in reliance on proposed § 1.987–
14(a)(1) (and would not need to follow
the other parts of the proposed
regulations, except to the extent
provided in the prior sentence).’’
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations
Section, Associate Chief Counsel (Procedure
and Administration).
[FR Doc. 2023–26785 Filed 12–5–23; 8:45 am]
BILLING CODE 4830–01–P
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1, 5, 301, and 602
[REG–134420–10]
RIN 1545–BJ87
Revising Consolidated Return
Regulations To Reflect Statutory
Changes, Modernize Language, and
Enhance Clarity; Correction
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking;
correction.
AGENCY:
This document corrects a
notice of proposed rulemaking (REG–
134420–10) published in the Federal
Register on August 7, 2023, modifying
regulations applicable to affiliated and
controlled groups of corporations in
order to reflect statutory changes,
update language to remove antiquated
or regressive terminology, and enhance
clarity. The correction makes parallel
amendments to similar regulations
applicable to controlled groups of
corporations.
SUMMARY:
The comment period for REG–
134420–10 (88 FR 52057, August 7,
2023) is reopened, and additional
written or electronic comments and
requests for a public hearing must be
received by February 5, 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–134420–10). 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
comment submitted to its public docket.
Send paper submissions to:
DATES:
E:\FR\FM\06DEP1.SGM
06DEP1
]]>Agencies
[Federal Register Volume 88, Number 233 (Wednesday, December 6, 2023)]
[Proposed Rules]
[Page 84770]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-26785]
[[Page 84770]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-132422-17]
RIN 1545-BO07
Income and Currency Gain or Loss With Respect to a Qualified
Business Unit; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; correction.
-----------------------------------------------------------------------
SUMMARY: This document contains a correction to a notice of proposed
rulemaking that was published in the Federal Register on Tuesday,
November 14, 2023. The proposed regulations provide guidance relating
to the determination of taxable income or loss and foreign currency
gain or loss with respect to a qualified business unit.
DATES: Written or electronic comments and requests for a public hearing
are still being accepted and must be received by February 12, 2024.
ADDRESSES: Commenters are strongly encouraged to submit public comments
electronically via the Federal eRulemaking Portal at https://www.regulations.gov (indicate IRS and REG-132422-17) 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 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-132422-17), Room 5203, Internal
Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC
20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Raphael J. Cohen at (202) 317-6938; concerning submissions of comments,
requests for a public hearing, and access to a public hearing, Vivian
Hayes at (202) 317-6901 (not toll-free numbers) or by email to
[email protected] (preferred).
SUPPLEMENTARY INFORMATION:
Background
On November 14, 2023, the Federal Register published a notice of
proposed rulemaking and partial withdrawal of notice of proposed
rulemaking (REG-132422-17) at 88 FR 78134 (the proposed regulations).
The proposed regulations that are the subject of this correction are
issued under sections 861, 985 through 989, and 1502 of the Internal
Revenue Code.
Need for Correction
As published, the preamble to the proposed regulations contains
errors that may prove to be misleading. This document provides a
technical correction to the preamble, which clarifies the misleading
paragraph.
Correction of Publication
Accordingly, the publication of the proposed regulations (REG-
132422-17), which was the subject of FR Doc. 2023-24649, published on
November 14, 2023, is corrected on page 78156, in the third column, by
revising the first full paragraph to read, ``Taxpayers may rely on the
proposed regulations (and so much of the final regulations as would not
be modified by the proposed regulations) for taxable years ending after
November 9, 2023, provided the taxpayer and each member of its
consolidated group and section 987 electing group consistently follow
the proposed regulations in their entirety and in a consistent manner.
Additionally, for taxable years ending after November 9, 2023, and
beginning on or before December 31, 2024, taxpayers may rely on only
the applicability date provisions in proposed Sec. Sec. 1.861-
9(g)(2)(v), 1.985-5(g), 1.987-14(a), (c), and (d), 1.988-1(i), 1.988-
4(b)(2)(ii), and 1.989(a)-1(b)(4) and (d)(4), provided that: (1) the
taxpayer and each member of its consolidated group and section 987
electing group consistently follow those provisions in their entirety
and in a consistent manner for those taxable years; (2) with respect to
any terminating QBU to which proposed Sec. 1.987-14(a)(2) would apply
or partnership to which proposed Sec. 1.987-14(a)(3) would apply, the
taxpayer and each member of its consolidated group and section 987
electing group consistently follow all of the proposed regulations (and
so much of the final regulations as would not be modified by the
proposed regulations) in their entirety and in a consistent manner; and
(3) to the extent that, under proposed Sec. 1.987-14(c), proposed
Sec. 1.987-10 would be applied in lieu of prior Sec. 1.987-10, the
taxpayer and each member of its consolidated group and section 987
electing group consistently follow proposed Sec. 1.987-10 in its
entirety and in a consistent manner. Thus, for example, a calendar year
taxpayer that has consistently followed the method described in the
1991 proposed regulations could continue to follow that method for the
2024 taxable year in reliance on proposed Sec. 1.987-14(a)(1) (and
would not need to follow the other parts of the proposed regulations,
except to the extent provided in the prior sentence).''
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations Section, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2023-26785 Filed 12-5-23; 8:45 am]
BILLING CODE 4830-01-P
