Guidance on Passive Foreign Investment Companies; Hearing

• Citation: 84 FR 52835
• Record Number: 2019-21476
• Published date: 03 October 2019
• Court: Internal Revenue Service,Treasury Department

Federal Register, Volume 84 Issue 192 (Thursday, October 3, 2019)

[Federal Register Volume 84, Number 192 (Thursday, October 3, 2019)]
                [Proposed Rules]
                [Page 52835]
                From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
                [FR Doc No: 2019-21476]
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                DEPARTMENT OF THE TREASURY
                Internal Revenue Service
                26 CFR Part 1
                [REG-105474-18]
                RIN 1545-BO59, 1545-BM69
                Guidance on Passive Foreign Investment Companies; Hearing
                AGENCY: Internal Revenue Service (IRS), Treasury.
                ACTION: Proposed rule; notice of hearing.
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                SUMMARY: This document provides a notice of public hearing on proposed
                regulations under sections 1291, 1297, and 1298 of the Internal Revenue
                Code (``Code'') regarding the determination of ownership in a passive
                foreign investment company within the meaning of section 1297(a)
                (``PFIC'') and the treatment of certain income received or accrued by a
                foreign corporation and assets held by a foreign corporation for
                purposes of section 1297.
                DATES: The public hearing is being held on Monday, December 9, 2019, at
                10:00 a.m. The IRS must receive speakers' outlines of the topics to be
                discussed at the public hearing by Friday, November 22, 2019. If no
                outlines are received by November 22, 2019, the public hearing will be
                cancelled.
                ADDRESSES: The public hearing is being held in the IRS Auditorium,
                Internal Revenue Service Building, 1111 Constitution Avenue NW,
                Washington, DC 20224. Due to building security procedures, visitors
                must enter at the Constitution Avenue entrance. In addition, all
                visitors must present a valid photo identification to enter the
                building. Send Submissions to CC:PA:LPD:PR (REG-105474-18), Room 5205,
                Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
                Washington, DC 20044. Submissions may be hand-delivered Monday through
                Friday to CC:PA:LPD:PR (REG-105474-18), Couriers Desk, Internal Revenue
                Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent
                electronically via the Federal eRulemaking Portal at
                www.regulations.gov (IRS REG-105474-18).
                FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
                Josephine Firehock at (202) 317-4932 (for the PFIC Insurance Exception)
                or Jorge M. Oben at (202) 317-6934 (for general rules, including
                indirect ownership and look-through rules); concerning submissions of
                comments, the hearing and/or to be placed on the building access list
                to attend the hearing, Regina Johnson at (202) 317-6901 (not toll-free
                numbers), [email protected].
                SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
                notice of proposed rulemaking (REG-105474-18) that was published in the
                Federal Register on Thursday, July 11, 2019 (84 FR 33120).
                 The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
                wish to present oral comments at the hearing that submitted written
                comments by September 9, 2019, must submit an outline of the topics to
                be addressed and the amount of time to be devoted to each topic by
                Friday, November 22, 2019.
                 A period of 10 minutes is allotted to each person for presenting
                oral comments. After the deadline for receiving outlines has passed,
                the IRS will prepare an agenda containing the schedule of speakers.
                Copies of the agenda will be made available, free of charge, at the
                hearing or by contacting the Publications and Regulations Branch at
                (202) 317-6901(not a toll-free number).
                 Because of access restrictions, the IRS will not admit visitors
                beyond the immediate entrance area more than 30 minutes before the
                hearing starts. For information about having your name placed on the
                building access list to attend the hearing, see the FOR FURTHER
                INFORMATION CONTACT section of this document.
                Crystal Pemberton,
                Senior Federal Liaison, Publications and Regulations Branch, Legal
                Processing Division, Associate Chief Counsel, (Procedure and
                Administration).
                [FR Doc. 2019-21476 Filed 10-2-19; 8:45 am]
                 BILLING CODE 4830-01-P