Proposed Rule2023-02574
Guidance Related to the Foreign Tax Credit; Hearing
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
February 7, 2023
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document provides a notice of public hearing on proposed regulations relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery requirement, and the attribution rule for withholding tax on royalty payments.
Full Text
<html>
<head>
<title>Federal Register, Volume 88 Issue 25 (Tuesday, February 7, 2023)</title>
</head>
<body><pre>
[Federal Register Volume 88, Number 25 (Tuesday, February 7, 2023)]
[Proposed Rules]
[Page 7903]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-02574]
[[Page 7903]]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-112096-22]
RIN 1545-BQ46
Guidance Related to the Foreign Tax Credit; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; notice of hearing.
-----------------------------------------------------------------------
SUMMARY: This document provides a notice of public hearing on proposed
regulations relating to the foreign tax credit, including guidance with
respect to the reattribution asset rule for purposes of allocating and
apportioning foreign taxes, the cost recovery requirement, and the
attribution rule for withholding tax on royalty payments.
DATES: The public hearing is being held on Wednesday, February 15,
2023, at 10 a.m. EDT. The IRS must receive speakers' outlines of the
topics to be discussed at the public hearing by Friday, February 10,
2023.
ADDRESSES: The public hearing is being held by teleconference.
Individuals that have submitted an outline of testimony and want to
testify (by telephone) at the public hearing must send an email to
<a href="/cdn-cgi/l/email-protection#572722353b3e343f3236253e393024173e252479303821"><span class="__cf_email__" data-cfemail="364643545a5f555e5357445f585145765f444518515940">[email protected]</span></a> to receive the telephone number and access code
for the hearing. The subject line of the email must contain the
regulation number [REG-112096-22] and the word TESTIFY. For example,
the subject line may say: Request to TESTIFY at Hearing for REG-112096-
22. The email must include the name(s) of the speaker(s) and title(s)
only. No outlines will be accepted by email. Send outline submissions
electronically via the Federal eRulemaking Portal at
<a href="http://www.regulations.gov">www.regulations.gov</a> (IRS REG-112096-22). The email must be received by
February 10, 2023.
FOR FURTHER INFORMATION CONTACT: Concerning Sec. Sec. 1.901-2 and
1.903-1, Teisha Ruggiero, (646) 259-8116, Sec. 1.861-20, Suzanne
Walsh, (202) 317-4908; concerning submissions of comments, the hearing,
and the access code to attend the hearing by teleconferencing, Vivian
Hayes at (202) 317-5306 (not toll-free numbers) or
<a href="/cdn-cgi/l/email-protection#1d6d687f71747e75787c6f74737a6e5d746f6e337a726b"><span class="__cf_email__" data-cfemail="304045525c595358555142595e5743705942431e575f46">[email protected]</span></a>. If emailing, please include Attend, Testify, or
Agenda Request and [REG-112096-22] in the email subject line.
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking REG-112096-22 that was published in the
Federal Register on Tuesday, November 22, 2022, 87 FR 71271.
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
previously submitted written comments by January 23, 2023, must submit
an outline on the topics to be addressed and the amount of time to be
devoted to each topic by February 10, 2023. A period of 10 minutes is
allotted to each person for presenting oral comments.
After receiving outlines, the IRS will prepare an agenda containing
the schedule of speakers. The agenda will be available via Federal
eRulemaking Portal (www.Regulations.gov) under the title of Supporting
& Related Material by February 12, 2023. The public hearing agenda will
contain the telephone number and access code.
Individuals who want to attend (by telephone) the public hearing
must also send an email to <a href="/cdn-cgi/l/email-protection#9dede8fff1f4fef5f8fceff4f3faeeddf4efeeb3faf2eb"><span class="__cf_email__" data-cfemail="90e0e5f2fcf9f3f8f5f1e2f9fef7e3d0f9e2e3bef7ffe6">[email protected]</span></a> to receive the
telephone number and access code for the hearing. The subject line of
the email must contain the regulation number [REG-112096-22] and the
word ATTEND. For example, the subject line may say: Request to ATTEND
Hearing for REG-112096-22. The email requesting to attend the public
hearing must be received by 5 p.m. EDT 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 <a href="/cdn-cgi/l/email-protection#661613040a0f050e0307140f080115260f141548010910"><span class="__cf_email__" data-cfemail="39494c5b55505a515c584b50575e4a79504b4a175e564f">[email protected]</span></a> (preferred) or by telephone
at (202) 317-5306 (not a toll-free number) by Friday, February 10,
2023.
Any questions regarding speaking at or attending a public hearing
may also be emailed to <a href="/cdn-cgi/l/email-protection#19696c7b75707a717c786b70777e6a59706b6a377e766f"><span class="__cf_email__" data-cfemail="6b1b1e09070208030e0a1902050c182b021918450c041d">[email protected]</span></a>.
Oluwafunmilayo A. Taylor,
Branch Chief, Publications and Regulations Branch, Legal Processing
Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2023-02574 Filed 2-6-23; 8:45 am]
BILLING CODE 4830-01-P
</pre><script data-cfasync="false" src="/cdn-cgi/scripts/5c5dd728/cloudflare-static/email-decode.min.js"></script></body>
</html>Indexed from Federal Register on February 7, 2023.
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.