[Federal Register Volume 64, Number 153 (Tuesday, August 10, 1999)]
[Proposed Rules]
[Pages 43323-43324]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-19929]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-252487-96]
RIN 1545-AX25
Inbound Grantor Trusts With Foreign Grantors
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking by cross reference to temporary
regulations.
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SUMMARY: The IRS is proposing regulations relating to the definition of
the term grantor for purposes of part I of subchapter J, chapter 1 of
the Internal Revenue Code. The text of temporary regulations published
elsewhere in this issue of the Federal Register, also serves as the
text of these proposed regulations. This document also provides notice
of a public hearing on these proposed regulations.
DATES: Written or electronic comments must be received by October 12,
1999. Requests to speak (with outlines of oral comments to be
discussed) at the public hearing scheduled for November 2, 1999, at 10
a.m. must be submitted by October 12, 1999.
ADDRESSES: Send submissions to: CC:DOM:CORP:R (REG-252487-96), room
5226, Internal Revenue Service, POB 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand delivered between the
hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:R (REG-252487-96), Courier's
Desk, Internal Revenue Service, 1111 Constitution Avenue, NW.,
Washington, DC. Alternatively, taxpayers may submit comments
electronically via the Internet by selecting the ``Tax Regs'' option on
the IRS Home Page, or by submitting comments directly to the IRS
Internet site at http://www.irs.ustreas.gov/tax__regs/regslist.html.
The public hearing will be held in room 2615, Internal Revenue
Building, 1111 Constitution Avenue, NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: Concerning the regulations, James A.
Quinn, (202) 622-3060; concerning submissions and the hearing, Guy R.
Traynor, (202) 622-7180 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
Temporary regulations in the Rules and Regulations section of this
issue of the Federal Register amend the Income Tax Regulations (26 CFR
part 1) relating to section 671. The temporary regulations contain
rules relating to the definition of grantor for purposes of part I of
subchapter J, chapter 1 of the Internal Revenue Code.
The text of those temporary regulations also serves as the text of
these proposed regulations. The preamble to the temporary regulations
explains the temporary regulations.
Special Analyses
It has been determined that this notice of proposed rulemaking is
not a significant regulatory action as defined in Executive Order
12866. Therefore, a regulatory assessment is not required. It also has
been determined that section 553(b) of the Administrative Procedure Act
(5 U.S.C. chapter 5) does not apply to these regulations, and because
the regulation does not impose a collection of information on small
entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not
apply. Pursuant to section 7805(f) of the Internal Revenue Code, this
notice of proposed rulemaking will be submitted to the Chief Counsel
for Advocacy of the Small Business Administration for comment on its
impact on small business.
Comments and Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any written comments (preferably a
signed original and eight (8) copies) that are submitted timely to the
IRS. The IRS and Treasury Department specifically request comments on
the clarity of the proposed regulations and how they can be made easier
to understand. All comments will be available for public inspection and
copying.
A public hearing has been scheduled for November 2, 1999, at 10
a.m. in room 2615, Internal Revenue Building, 1111 Constitution Avenue,
NW., Washington DC. Because of access restrictions, visitors will not
be admitted beyond the Internal Revenue Building lobby more than 15
minutes before the hearing starts.
The rules of 26 CFR 601.601(a)(3) apply to the hearing.
Persons that wish to present oral comments at the hearing must
submit written comments by October 12, 1999, and submit an outline of
the topics to be discussed and the time to be devoted to each topic
(preferably a signed original and eight (8) copies) by October 12,
1999.
A period of 10 minutes will be allotted to each person for making
comments.
An agenda showing the scheduling of the speakers will be prepared
after the deadline for receiving outlines has passed. Copies of the
agenda will be available free of charge at the hearing.
Drafting information. The principal author of these regulations is
James A. Quinn of the Office of Assistant Chief Counsel (Passthroughs
and Special Industries). However, other personnel from the IRS and
Treasury Department participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
PART 1--INCOME TAXES
Paragraph 1. The authority citation for part 1 continues to read as
follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. In Sec. 1.671-2, paragraph (e) is revised to read as
follows:
Sec. 1.671-2 Applicable principles.
* * * * *
[[Page 43324]]
(e) [The text of this proposed paragraph (e) is the same as the
text of Sec. 1.671-2T(e) published elsewhere in this issue of the
Federal Register].
John M. Dalrymple,
Acting Deputy Commissioner of Internal Revenue.
[FR Doc. 99-19929 Filed 8-5-99; 2:09 pm]
BILLING CODE 4830-01-P
