Department of the Treasury September 2014 – Federal Register Recent Federal Regulation Documents
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Pricing for the 2015 United States Marshals 225th Anniversary Commemorative Coin Program
The United States Mint is announcing pricing for the 2015 United States Marshals 225th Anniversary Commemorative Coin Program as follows:
Senior Executive Service; Combined Performance Review Board (PRB)
This notice announces the appointment of the members of the Combined Performance Review Board (PRB) for the United States Mint, the Fiscal Service (FS), the Financial Crimes Enforcement Network (FinCEN), the Bureau of Engraving and Printing (BEP), and the Alcohol and Tobacco Tax and Trade Bureau (TTB). The Combined PRB reviews the performance appraisals of career senior executives below the level of the bureau head who are not assigned to the immediate Office of the Director of each bureau represented by the Combined PRB. The Combined PRB makes recommendations regarding proposed performance appraisals, ratings, bonuses, pay adjustments, and other appropriate personnel actions. Membership is effective on September 30, 2014. Composition of the United States Treasury CPRB, including names and titles, is as follows:
Small Brewers Bond Reduction and Requirement To File Tax Returns, Remit Tax Payments and Submit Reports Quarterly
The Alcohol and Tobacco Tax and Trade Bureau (TTB) is adopting as a permanent regulatory change a flat $1,000 penal sum for the brewer's bond for brewers whose excise tax liability is reasonably expected to be not more than $50,000 in a given calendar year and who were liable for not more than $50,000 in such taxes in the preceding calendar year. TTB originally set forth this change in a temporary rule issued on December 7, 2012. In addition, TTB is adopting as a final rule its proposal, also issued on December 7, 2012, to require small brewers to file Federal excise tax returns, pay tax, and submit reports of operations quarterly. TTB expects these amendments to reduce the regulatory burdens on such brewers, reduce their administrative costs, and create administrative efficiencies for TTB.
Proposed Collection; Comment Request for Form 8858 and Sch. M
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8858, Information Return of U.S. Persons With Respect To Foreign Disregarded Entities, and Schedule M, Transaction Between Foreign Disregarded Entity of a Foreign Tax Owner and the Filer on Other Related Entities.
Proposed Collection
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8804-C, Certificate of Partner-Level Items to Reduce Section 1446 Withholding, and Special Rules to Reduce Section 1446 Withholding.
Employee Retirement Benefit Plan Returns Required on Magnetic Media
This document contains final regulations relating to the requirements for filing certain employee retirement benefit plan statements, returns, and reports on magnetic media. The term magnetic media includes electronic filing, as well as other magnetic media specifically permitted under applicable regulations, revenue procedures, publications, forms, instructions, or other guidance on the IRS.gov Internet Web site. These regulations affect plan administrators and employers maintaining retirement plans that are subject to various employee benefit reporting requirements under the Internal Revenue Code (Code).
Community Development Financial Institutions Fund
Through the CDFI Program, the CDFI Fund provides (i) FA awards of up to $1 million to Certified Community Development Financial Institutions (CDFIs) serving Native American, Alaska Native, or Native Hawaiian populations or Native American areas defined as Federally-designated reservations, Hawaiian homelands, Alaska Native Villages and U.S. Census Bureau-designated Tribal Statistical Areas (collectively, ``Native Communities'') to build their financial capacity to lend to their Target Markets, and (ii) TA grants of up to $150,000 to build Certified, Certifiable, and Emerging CDFIs' organizational capacity to serve their Target Markets and Sponsoring Entities ability to create Certified CDFIs that serve Native Communities. All awards provided through this NOFA are subject to funding availability.
Funding Opportunity Title: Notice of Funds Availability (NOFA) Inviting Applications for Financial Assistance (FA) Awards or Technical Assistance (TA) Grants Under the Community Development Financial Institutions Program (CDFI Program) FY 2015 Funding Round
Through the CDFI Program, the CDFI Fund provides (i) FA awards of up to $2 million to Certified Community Development Financial Institutions (CDFIs) to build their financial capacity to lend to their Target Markets, and (ii) TA grants of up to $125,000 to build Certified, Certifiable, and Emerging CDFIs' organizational capacity to serve their Target Markets. All awards provided through this NOFA are subject to funding availability.
Departmental Offices; Privacy Act of 1974, as Amended; System of Records Notice
In accordance with the Privacy Act of 1974, as amended, 5 U.S.C. 552a, the Department of the Treasury gives notice that it proposes to add a new system of records to its inventory, ``Treasury/ DO. 411Intelligence Enterprise Files,'' to be maintained by the Office of Intelligence and Analysis.
Public Input on the Establishment of Financial Data Standards (Data Exchange)
The Digital Accountability and Transparency Act of 2014 (DATA Act) was enacted for purposes that include expanding the Federal Funding Accountability and Transparency Act of 2006 (FFATA) to require the disclosure of direct Federal agency expenditures and information that links ``Federal . . . spending information to programs of Federal agencies to enable taxpayers and policy makers to track Federal spending more effectively.'' Public Law 113-101, 2(1). FFATA, as amended by the DATA Act, requires the Secretary of the Treasury (Treasury) and the Director of the Office of Management and Budget (OMB), in consultation with the heads of Federal agencies, to ``establish Government-wide financial data standards for any Federal funds made available to or expended by Federal agencies and entities receiving Federal funds.'' 31 U.S.C. 6101, note, Sec. 4(a)(1). Treasury and OMB shall consult with public and private stakeholders in establishing the Government-wide financial data standards (data standards). 31 U.S.C. 6101, note, 4(d). The DATA Act provides that Treasury and OMB shall issue guidance to Federal agencies on the established data standards no later than one year after DATA Act enactment, i.e., by May 9, 2015. Under this Notice, Treasury asks for input from public and private stakeholders on several data standards topics and questions, specifically on data exchange, to better ensure the data standards to be established by Treasury and OMB are informed and useful, and to ensure compliance with DATA Act consultation requirements. Treasury will share all input or information received with OMB to ensure the proper establishment of data standards by Treasury and OMB, consistent with DATA Act requirements.
Proposed Collection; Comment Request for Regulation Project
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13(44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning an existing transfers by domestic corporations that are subject to section 367(a)(5); distributions by domestic corporations that are subject to section 1248(f).
Awards for Information Relating to Detecting Underpayments of Tax or Violations of the Internal Revenue Laws; Correction
This document contains corrections to final regulations (TD 9687) that were published in the Federal Register on Tuesday, August 12, 2014 (79 FR 47246). The final regulations provide comprehensive guidance for the award program authorized under Internal Revenue Code (Code) section 7623.
Awards for Information Relating to Detecting Underpayments of Tax or Violations of the Internal Revenue Laws; Correction
This document contains corrections to final regulations (TD 9687) that were published in the Federal Register on Tuesday, August 12, 2014 (79 FR 47246). The final regulations provide comprehensive guidance for the award program authorized under Internal Revenue Code (Code) section 7623.
Branded Prescription Drug Fee; Correction
This document contains corrections to final regulations, temporary regulations, and removal of temporary regulations (TD 9684) that were published in the Federal Register on Monday, July 28, 2014 (79 FR 43631). The final regulations provide guidance on the annual fee imposed on covered entities engaged in the business of manufacturing branded prescription drugs.
Branded Prescription Drug Fee; Correction
This document contains corrections to final regulations (TD 9684) that were published in the Federal Register on Monday, July 28, 2014 (79 FR 43631). The final regulations provide guidance on the annual fee imposed on covered entities engaged in the business of manufacturing branded prescription drugs.
Branded Prescription Drug Fee; Correction
This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-123286-14) that was published in the Federal Register on Monday, July 28, 2014 (79 FR 43699). The proposed regulations relate to the branded prescription drug fee. The proposed regulations modify the definition of controlled group for purposes of the branded prescription drug fee.
Margin and Capital Requirements for Covered Swap Entities
The OCC, Board, FDIC, FCA, and FHFA (each an ``Agency'' and, collectively, the ``Agencies'') are seeking comment on a proposed joint rule to establish minimum margin and capital requirements for registered swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants for which one of the Agencies is the prudential regulator. This proposed rule implements sections 731 and 764 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which require the Agencies to adopt rules jointly to establish capital requirements and initial and variation margin requirements for such entities and their counterparties on all non- cleared swaps and non-cleared security-based swaps in order to offset the greater risk to such entities and the financial system arising from the use of swaps and security-based swaps that are not cleared.
Joint Report: Differences in Accounting and Capital Standards Among the Federal Banking Agencies as of December 31, 2013; Report to Congressional Committees
The OCC, the Board, and the FDIC (collectively, the agencies) have prepared this report pursuant to section 37(c) of the Federal Deposit Insurance Act. Section 37(c) requires the agencies to jointly submit an annual report to the Committee on Financial Services of the U.S. House of Representatives and to the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate describing differences between the accounting and capital standards used by the agencies. The report must be published in the Federal Register.
Agency Information Collection Activities; Information Collection Renewal; Submission for OMB Review; Basel II Interagency Supervisory Guidance for the Supervisory Review Process (1557-0242; 3064-0165)
The agencies, as part of their continuing effort to reduce paperwork and respondent burden, invite the general public and other Federal agencies to comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). An agency may not conduct or sponsor, and a respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The agencies are soliciting comment concerning the renewal of their information collection titled ``Basel II Interagency Supervisory Guidance for the Supervisory Review Process (Pillar 2),'' and giving notice that they are sending the collection to OMB for review.
The $500,000 Deduction Limitation for Remuneration Provided by Certain Health Insurance Providers
This document contains final regulations on the application of the $500,000 deduction limitation for remuneration provided by certain health insurance providers under section 162(m)(6) of the Internal Revenue Code (Code). These regulations affect certain health insurance providers providing remuneration that exceeds the deduction limitation.
Additional Designations, Foreign Narcotics Kingpin Designation Act
The U.S. Department of the Treasury 's Office of Foreign Assets Control (``OFAC'') is publishing the names of eight individuals whose property and interests in property have been blocked pursuant to the Foreign Narcotics Kingpin Designation Act (``Kingpin Act'') (21 U.S.C. 1901-1908, 8 U.S.C. 1182).
Privacy Act of 1974, as Amended; System of Records
In accordance with the Privacy Act of 1974, as amended, 5 U.S.C. 552a, the Department of the Treasury, Bureau of the Fiscal Service (Fiscal Service) proposes to establish a new Privacy Act system of records entitled, ``Department of the Treasury/Bureau of the Fiscal Service .024OneVoice Customer Relationship Management.'' This system of records allows the Fiscal Service to collect and maintain records that will allow the bureau to manage its customer interactions with its external ``business'' customers and vendors.
Removal of Allocation Rule for Disbursements From Designated Roth Accounts to Multiple Destinations
This document contains proposed amendments to the regulations that address the tax treatment of distributions from designated Roth accounts under tax-favored retirement plans. The proposed regulations would limit the applicability of the rule regarding the allocation of after-tax amounts when disbursements are made to multiple destinations so the allocation rule applies only to distributions made before the earlier of January 1, 2015 or a date chosen by the taxpayer that is on or after September 18, 2014. These regulations would affect administrators of, employers maintaining, participants in, and beneficiaries of designated Roth accounts under tax-favored retirement plans.
Proposed Information Collection; Comment Request
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)).
Additional Rules Regarding Hybrid Retirement Plans
This document contains final regulations providing guidance relating to applicable defined benefit plans. Applicable defined benefit plans are defined benefit plans that use a lump sum-based benefit formula, including cash balance plans and pension equity plans, as well as other hybrid retirement plans that have a similar effect. These regulations provide guidance relating to certain provisions that apply to applicable defined benefit plans that were added to the Internal Revenue Code (Code) by the Pension Protection Act of 2006, as amended by the Worker, Retiree, and Employer Recovery Act of 2008. These regulations affect sponsors, administrators, participants, and beneficiaries of these plans.
Transitional Amendments To Satisfy the Market Rate of Return Rules for Hybrid Retirement Plans
This document contains proposed regulations that would provide guidance regarding certain amendments to applicable defined benefit plans. Applicable defined benefit plans are defined benefit plans that use a lump sum-based benefit formula, including cash balance plans and pension equity plans, as well as other hybrid retirement plans that have a similar effect. These proposed regulations would permit an applicable defined benefit plan that does not comply with the requirement that the plan not provide for interest credits (or equivalent amounts) at an effective rate that is greater than a market rate of return to comply with that requirement by changing to an interest crediting rate that is permitted under the final hybrid plan regulations, without violating the anti-cutback rules of section 411(d)(6). These regulations would affect sponsors, administrators, participants, and beneficiaries of these plans. This document also provides a notice of a public hearing on these proposed regulations.
Agency Information Collection Activities; Comment Request; Renewal Without Change of Bank Secrecy Act Suspicious Activity and Currency Transaction Reporting Requirements
FinCEN, a bureau of the U.S. Department of the Treasury (``Treasury''), invites all interested parties to comment on its proposed renewal without change of the Bank Secrecy Act (``BSA'') Suspicious Activity Reporting requirements for certain financial institutions, i.e., depository institutions, casinos and card clubs, and insurance companies. This notice also proposes to renew without change the Currency Transaction Reporting requirement for certain financial institutions, i.e., depository institutions, money services businesses, brokers or dealers in securities, mutual funds, futures commission merchants and introducing brokers in commodities, and casinos and card clubs. FinCEN intends to submit these requirements for approval by the Office of Management and Budget (``OMB'') of a three- year extension of Control Numbers 1506-0001, 1506-0004, 1506-0005, 1506-0006, and 1506-0029. This request for comments is made pursuant to the Paperwork Reduction Act (``PRA'') of 1995, Public Law 104-13, 44 U.S.C. 3506(c)(2)(A).
Unblocking of a Specially Designated National and Blocked Person Pursuant to Executive Order 13566
The Treasury Department's Office of Foreign Assets Control (OFAC) is removing the name of one individual whose property and interests in property have been unblocked pursuant to Executive Order 13566 of February 25, 2011, ``Blocking Property and Prohibiting Certain Transactions Related to Libya.''
Additional Designations, Foreign Narcotics Kingpin Designation Act
The U.S. Department of the Treasury's Office of Foreign Assets Control (``OFAC'') is publishing the names of three individuals and one entity whose property and interests in property have been blocked pursuant to the Foreign Narcotics Kingpin Designation Act (``Kingpin Act'') (21 U.S.C. 1901-1908, 8 U.S.C. 1182).
Treasury Inspector General for Tax Administration; Privacy Act of 1974, as Amended: Computer Matching Program
Pursuant to 5 U.S.C. 552a, the Privacy Act of 1974, as amended, notice is hereby given of the agreement between the Treasury Inspector General for Tax Administration (TIGTA) and the Internal Revenue Service (IRS) concerning the conduct of TIGTA's computer matching program.
Authority for Voluntary Withholding on Other Payments
This document contains final regulations under section 3402(p) of the Internal Revenue Code (Code) relating to voluntary withholding agreements. The final regulations allow the Secretary to issue guidance in the Internal Revenue Bulletin to describe payments for which the Secretary finds that income tax withholding under a voluntary withholding agreement would be appropriate. The regulations affect persons making and persons receiving payments for which the IRS issues subsequent guidance authorizing the parties to enter into voluntary withholding agreements.
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Fair Housing Home Loan Data System Regulation
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning renewal of its information collection titled, ``Fair Housing Home Loan Data System Regulation.'' The OCC is also giving notice that it has sent the collection to OMB for review.
Proposed Collection; Comment Request for Regulations Project
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning statement of liability of lender, surety, or other person for withholding taxes.
Open Meeting of the Taxpayer Advocacy Panel Taxpayer Assistance Center Improvements Project Committee
An open meeting of the Taxpayer Advocacy Panel Taxpayer Assistance Center Improvements Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee
An open meeting of the Taxpayer Advocacy Panel Tax Forms and Publications Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Toll-Free Phone Line Project Committee
An open meeting of the Taxpayer Advocacy Panel Toll-Free Phone Line Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Notices and Correspondence Project Committee
An open meeting of the Taxpayer Advocacy Panel Notices and Correspondence Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Taxpayer Communications Project Committee
An open meeting of the Taxpayer Advocacy Panel Taxpayer Communications Project Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Joint Committee
An open meeting of the Taxpayer Advocacy Panel Joint Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Update of Entities and Vessels Identified Pursuant to the Iranian Transactions and Sanctions Regulations and Executive Order 13599
The Treasury Department's Office of Foreign Assets Control (``OFAC'') is publishing updated information of eight entities and eight vessels previously identified as the Government of Iran or as property of the Government of Iran under the Iranian Transactions and Sanctions Regulations (the ``ITSR''), 31 CFR Part 560, and Executive Order 13599, and has revised the entries on OFAC's list of Specially Designated Nationals and Blocked Persons to reflect the new information.
Sanctions Actions Pursuant to Executive Orders 13224, 13382, 13599, 13622, 13645, and the Iranian Transactions and Sanctions Regulations
The Treasury Department's Office of Foreign Assets Control (OFAC) is publishing the names of 22 persons whose property and interests in property are blocked pursuant to one or more of the following authorities: Executive Order (E.O.) 13224, 13382, E.O. 13599, E.O. 13622, E.O. 13645, and the Iranian Transactions and Sanctions Regulations (ITSR), as well as the names of 6 vessels that OFAC has identified as blocked property of one or more person whose property and interests in property are blocked. Finally, OFAC is publishing revised information for 2 persons on OFAC's list of Specially Designated Nationals and Blocked Persons (SDN List).
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Loans in Areas Having Special Flood Hazards
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning its information collection titled, ``Loans in Areas Having Special Flood Hazards.'' The OCC is also giving notice that it has sent the collection to OMB for review.
Proposed Collection; Comment Request for Regulation Project
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning an agent for consolidated group and Revenue Procedure 2002-43, Determination of a Substitute Agent for a Consolidated Group.
Surety Companies Acceptable on Federal Bonds: Amendment-Integrand Assurance Company
This is Supplement No. 1 to the Treasury Department Circular 570, 2014 Revision, published July 1, 2014, at 79 FR 37398.
Notification of Citizens Coinage Advisory Committee September 23-24, 2014, Public Meeting
Pursuant to United States Code, Title 31, section 5135(b)(8)(C), the United States Mint announces the Citizens Coinage Advisory Committee (CCAC) public meeting scheduled for September 23-24, 2014. Date: September 23-24, 2014. Time: September 23 9:30 a.m. to 4:30 p.m.; September 24 9:00 a.m. to 12:00 p.m. Location: Conference Rooms B & C, United States Mint, 801 9th Street NW., Washington, DC 20220. Subject: Review and consideration of candidate designs for the 2015 and 2016 First Spouse Bullion Coin Program, the 2015 and 2016 American Eagle Platinum Bullion Coin Program, and the 2016 America the Beautiful Quarters[supreg] Program Coins honoring Shawnee National Forest, Cumberland Gap National Historical Park, Harpers Ferry National Historical Park, Theodore Roosevelt National Park, and Fort Moultrie (Fort Sumter National Monument); review and consideration of additional tribal candidate designs for the Fond du Lac Band of Lake Superior Chippewa Code Talkers Recognition Congressional Medals; review and consideration of candidate designs for the World War II Members of the Civil Air Patrol Congressional Gold Medal; discussion of a proposed art medal program; and discussion of the FY2014 Annual Report. Interested persons should call the CCAC HOTLINE at (202) 354-7502 for the latest update on meeting time and room location. In accordance with 31 U.S.C. 5135, the CCAC: [ssquf] Advises the Secretary of the Treasury on any theme or design proposals relating to circulating coinage, bullion coinage, Congressional Gold Medals, and national and other medals. [ssquf] Advises the Secretary of the Treasury with regard to the events, persons, or places to be commemorated by the issuance of commemorative coins in each of the five calendar years succeeding the year in which a commemorative coin designation is made. [ssquf] Makes recommendations with respect to the mintage level for any commemorative coin recommended.
Proposed Collection; Comment Request for Regulation Project.
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). The IRS is soliciting comments concerning information collection requirements related to Return Requirement for United States Persons Acquiring or Disposing of an Interest in a Foreign Partnership, or Whose Proportional Interest in a Foreign Partnership Changes.
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