Consolidated Returns; Intercompany Obligations

Federal Register: February 25, 2008 (Volume 73, Number 37)

Proposed Rules

Page 9971-9972

From the Federal Register Online via GPO Access [wais.access.gpo.gov]

DOCID:fr25fe08-16

DEPARTMENT OF THE TREASURY

Internal Revenue Service 26 CFR Part 1

REG-107592-00

RIN 1545-BA11

Consolidated Returns; Intercompany Obligations

AGENCY: Internal Revenue Service (IRS), Treasury.

Page 9972

ACTION: Partial withdrawal of notice of proposed rulemaking.

SUMMARY: This document withdraws a portion of a notice of proposed rulemaking (REG-107592-00) published in the Federal Register on

September 28, 2007 (72 FR 55139). The withdrawn portion relates to the treatment of transactions involving the provision of insurance between members of a consolidated group.

FOR FURTHER INFORMATION CONTACT: Frances L. Kelly, (202) 622-7770 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

On September 28, 2007, the IRS and the Treasury Department published a notice of proposed rulemaking (REG-107592-00) in the

Federal Register (72 FR 55139) which proposed to amend Sec. 1.1502- 13(g) (regarding the treatment of transactions involving obligations between members of a consolidated group) and to add Sec. 1.1502- 13(e)(2)(ii)(C) (regarding the treatment of certain transactions involving the provision of insurance between members of a consolidated group).

Under proposed Sec. 1.1502-13(e)(2)(ii)(C), certain intercompany insurance transactions would be taken into account on a single entity basis. Written comments were received with respect to proposed Sec. 1.1502-13(e)(2)(ii)(C). After consideration of these comments, the IRS and the Treasury Department have decided to withdraw proposed Sec. 1.1502-13(e)(2)(ii)(C). However, the IRS and the Treasury Department continue to study whether revisions to the rules for intercompany transactions are necessary to clearly reflect the taxable income of consolidated groups.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Partial Withdrawal of a Notice of Proposed Rulemaking

Accordingly, under the authority of 26 U.S.C. 7805 and 26 U.S.C. 1502, Sec. 1.1502-13(e)(2)(ii)(C) of the notice of proposed rulemaking

(REG-107592-00) that was published in the Federal Register on September 28, 2007 (72 FR 55139) is withdrawn.

Linda E. Stiff,

Deputy Commissioner for Services and Enforcement.

FR Doc. 08-823 Filed 2-20-08; 8:48 am

BILLING CODE 4830-01-P