Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups; Hearing
| Published date | 01 May 2020 |
| Citation | 85 FR 25378 |
| Record Number | 2020-08842 |
| Section | Proposed rules |
| Court | Internal Revenue Service,Treasury Department |
Federal Register, Volume 85 Issue 85 (Friday, May 1, 2020)
[Federal Register Volume 85, Number 85 (Friday, May 1, 2020)]
[Proposed Rules]
[Page 25378]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08842]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-105495-19]
RIN 1545-BP21
Guidance Related to the Allocation and Apportionment of
Deductions and Foreign Taxes, Financial Services Income, Foreign Tax
Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g),
and Consolidated Groups; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Proposed rule; notification of hearing.
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SUMMARY: This document provides a notice of public hearing on proposed
regulations that provide guidance relating to the allocation and
apportionment of deductions and creditable foreign taxes, the
definition of financial services income, foreign tax redeterminations,
availability of foreign tax credits under the transition tax, and the
application of the foreign tax credit limitation to consolidated
groups.
DATES: The public hearing is being held on Wednesday, May 20, 2020, at
10:00 a.m. The IRS must receive speakers' outlines of the topics to be
discussed at the public hearing by Monday, May 11, 2020. If no outlines
are received by May 11, 2020, the public hearing will be cancelled.
ADDRESSES: The public hearing is being held by teleconference.
Individuals who want to testify (by telephone) at the public hearing
must send an email to [email protected] to receive the telephone
number and access code for the hearing. The subject line of the email
must contain the regulation number REG-105495-19 and the word TESTIFY.
For example, the subject line may say: Request to TESTIFY at Hearing
for REG-105495-19. The email should also include a copy of the
speaker's public comments and outline of topics. The email must be
received by May 11, 2020.
Individuals who want to attend (by telephone) the public hearing
must also send an email to [email protected] to receive the
telephone number and access code for the hearing. The subject line of
the email must contain the regulation number REG-105495-19 and the word
ATTEND. For example, the subject line may say: Request to ATTEND
Hearing for REG-105495-19. The email requesting to attend the public
hearing must be received by 5:00 p.m. two (2) business days before the
date that the hearing is scheduled.
The telephonic hearing will be made accessible to people with
disabilities. To request special assistance during the telephonic
hearing please contact the Publications and Regulations Branch of the
Office of Associate Chief Counsel (Procedure and Administration) by
sending an email to [email protected] (preferred) or by telephone
at (202) 317-5177 (not a toll-free number) at least three (3) days
prior to the date that the telephonic hearing is scheduled.
Any questions regarding speaking at or attending a public hearing
may also be emailed to [email protected].
Send outline submissions electronically via the Federal eRulemaking
Portal at www.regulations.gov (IRS REG-105495-19).
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Jeffrey Cowan at (202) 317- 4924; concerning submissions of comments,
the hearing and/access code to attend the hearing by teleconferencing,
Regina Johnson at (202) 317-5177 (not toll-free numbers) or
[email protected].
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking REG-105495-19 that was published in the
Federal Register on December 17, 2019, 84 FR 69124.
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments telephonically at the hearing that
submitted written comments by February 18, 2020, must submit an outline
of the topics to be addressed and the amount of time to be devoted to
each topic by May 11, 2020.
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, on Regulations.gov, search
IRS and REG-105495-19, or by emailing your request to
[email protected].
Please put ``REG-105495-19 Agenda Request'' in the subject line of
the email.
Martin V. Franks,
Branch Chief, Publications and Regulations Branch, Legal Processing
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-08842 Filed 4-30-20; 8:45 am]
BILLING CODE 4830-01-P
