Proposed Rule2022-22891
Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
October 21, 2022
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document withdraws a notice of proposed rulemaking published in the Federal Register on August 29, 2006. The notice of proposed rulemaking relates to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Internal Revenue Code (the "Code") and related basis adjustments under section 961 of the Code.
Full Text
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<title>Federal Register, Volume 87 Issue 203 (Friday, October 21, 2022)</title>
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[Federal Register Volume 87, Number 203 (Friday, October 21, 2022)]
[Proposed Rules]
[Page 63981]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-22891]
[[Page 63981]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-121509-00]
RIN 1545-AY54
Exclusion From Gross Income of Previously Taxed Earnings and
Profits, and Adjustments to Basis of Stock in Controlled Foreign
Corporations and of Other Property
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Withdrawal of notice of proposed rulemaking.
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SUMMARY: This document withdraws a notice of proposed rulemaking
published in the Federal Register on August 29, 2006. The notice of
proposed rulemaking relates to the exclusion from gross income of
previously taxed earnings and profits under section 959 of the Internal
Revenue Code (the ``Code'') and related basis adjustments under section
961 of the Code.
DATES: The proposed regulations are withdrawn on October 21, 2022.
FOR FURTHER INFORMATION CONTACT: Joshua P. Roffenbender, (202) 317-
6934, or Chadwick Rowland, (202) 317-6937 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
On August 29, 2006, the Treasury Department and the IRS issued a
notice of proposed rulemaking relating to the exclusion from gross
income of previously taxed earnings and profits under section 959 and
related basis adjustments under section 961 (71 FR 51155), corrections
to which were published in the Federal Register on December 8, 2006 (71
FR 71116) (together, the ``2006 proposed regulations''). On December
14, 2018, the Treasury Department and the IRS issued Notice 2019-01
(2019-02 I.R.B. 275), which announced an intent to withdraw the 2006
proposed regulations and issue a new notice of proposed rulemaking
under sections 959 and 961 (the ``new proposed regulations'').
This document withdraws the 2006 proposed regulations. Those
proposed regulations were never finalized, never went into effect, and
did not indicate that taxpayers could rely on them. Withdrawing the
proposed regulations at this point will help prevent possible abuse or
other misuse of them--such as inappropriate basis adjustments in
certain stock acquisitions to which section 304(a)(1) applies--while
the Treasury Department and the IRS continue to develop the new
proposed regulations. The IRS may, where appropriate, challenge
taxpayer positions giving rise to inappropriate results.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Withdrawal of a Notice of Proposed Rulemaking
0
Accordingly, under the authority of 26 U.S.C. 7805, the notice of
proposed rulemaking (REG-121509-00) published in the Federal Register
on August 29, 2006 (71 FR 51155), corrections to which were published
in the Federal Register on December 8, 2006 (71 FR 71116), is
withdrawn.
Douglas W. O'Donnell,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2022-22891 Filed 10-20-22; 8:45 am]
BILLING CODE 4830-01-P
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</html>Indexed from Federal Register on October 21, 2022.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.