Department of Treasury August 4, 2006 – Federal Register Recent Federal Regulation Documents

The United States Mint is accepting applications from professional artists to fill up to ten new Associate Designer positions in its Artistic Infusion Program to help design United States coins and medals. The Artistic Infusion Program was created in 2003 to enrich and invigorate the design of United States coins and medals by developing a pool of professional artists (Master & Associate Designers) and college and graduate-level art students (Student Designers) in visual arts who will be invited to create and submit new designs for selected coin and medal programs throughout the year. The United States Mint encourages applications from talented artists, representing diverse backgrounds and a variety of interests reflecting those of the American people, who will look at coin design in new ways. Artists selected to participate in the program will be paid an established fee for their work, and those whose designs are used for certain coins and medals will be named as the designer in historical documents, including certificates of authenticity and promotional materials. Most important, the program provides the nation's most gifted artists with the opportunity to contribute beautiful designs to coins that will be enjoyed by all Americans. An orientation session and designer symposium will be held for artists selected to participate in the program (attending at the United States Mint's expense) at the United States Mint at Philadelphia in early 2007. This session's purpose will be to inform selected artists about the history of United States coin and medal design, the coin making process and upcoming design opportunities.

In a separate part to this issue of the Federal Register, the IRS is issuing temporary regulations relating to the treatment of controlled services transactions under section 482. These temporary regulations also provide guidance regarding the allocation of income from intangibles, in particular with respect to contribution by a controlled party to the value of an intangible owned by another controlled party as it relates to controlled services transactions and modify the regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482. The text of those regulations also serves as the text of these proposed regulations. These proposed regulations also contain a coordination rule with global dealing operations. The Treasury Department and the IRS are presently working on new global dealing regulations and intend that when final regulations are issued, those regulations, not Sec. 1.482-9T, will govern the evaluation of the activities performed by a global dealing operation within the scope of those regulations. Pending finalization of the global dealing regulations, taxpayers may rely on the proposed global dealing regulations, not the temporary services regulations, to govern financial transactions entered into in connection with a global dealing operation as defined in proposed Sec. 1.482-8. Therefore, proposed regulations under Sec. 1.482-9(m)(5) clarify that a controlled services transaction does not include a financial transaction entered into in connection with a global dealing operation. These proposed regulations potentially affect controlled taxpayers within the meaning of section 482. This document also provides notice of a public hearing on these proposed regulations.