Notice2023-25410
Proposed Collection; Comment Request for Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations
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
November 17, 2023
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning certain transfers of domestic stock or securities by U.S. persons to foreign corporations.
Full Text
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<title>Federal Register, Volume 88 Issue 221 (Friday, November 17, 2023)</title>
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[Federal Register Volume 88, Number 221 (Friday, November 17, 2023)]
[Notices]
[Page 80388]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-25410]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
Proposed Collection; Comment Request for Certain Transfers of
Domestic Stock or Securities by U.S. Persons to Foreign Corporations
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice and request for comments.
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SUMMARY: The Internal Revenue Service, as part of its continuing effort
to reduce paperwork and respondent burden, invites the general public
and other Federal agencies to take this opportunity to comment on
continuing information collections, as required by the Paperwork
Reduction Act of 1995. The IRS is soliciting comments concerning
certain transfers of domestic stock or securities by U.S. persons to
foreign corporations.
DATES: Written comments should be received on or before January 16,
2024 to be assured of consideration.
ADDRESSES: Direct all written comments to Andres Garcia, Internal
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC
20224 or by email to <a href="/cdn-cgi/l/email-protection#91e1e3f0bff2fefcfcf4ffe5e2d1f8e3e2bff6fee7"><span class="__cf_email__" data-cfemail="f7878596d994989a9a92998384b79e8584d9909881">[email protected]</span></a>. Please include the OMB
Control Number 1545-1478 or TD 8702 in the Subject line.
FOR FURTHER INFORMATION CONTACT: Requests for additional information or
copies of the form should be directed to Kerry Dennis, at (202) 317-
5744 or Internal Revenue Service, Room 6526, 1111 Constitution Avenue
NW, Washington, DC 20224, or through the internet, at
<a href="/cdn-cgi/l/email-protection#50233122317e3c7e333f26393e37243f3e103922237e373f26"><span class="__cf_email__" data-cfemail="a3d0c2d1c28dcf8dc0ccd5cacdc4d7cccde3cad1d08dc4ccd5">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Title: Certain Transfers of Domestic Stock or Securities by U.S.
Persons to Foreign Corporations.
OMB Number: 1545-1478.
Regulation Project Number: TD 8702.
Abstract: The regulation relates to certain transfers of stock or
securities of domestic corporations pursuant to the corporate
organization, reorganization, or liquidation provisions of the internal
Revenue Code. Transfers of stock or securities by U.S. persons in tax-
free transactions are treated as taxable transactions when the acquirer
is a foreign corporation, unless an exception applies under Code
section 367(a). This regulation provides that no U.S. person will
qualify for an exception unless the U.S. target company complies with
certain reporting requirements.
Current Actions: There are no changes being made to the regulations
at this time.
Type of Review: Extension of a currently approved collection.
Affected Public: Business or other for-profit organizations.
Estimated Number of Respondents: 100.
Estimated Time per Respondent: 10 minutes.
Estimated Total Annual Burden Hours: 1,000.
The following paragraph applies to all the collections of
information covered by this notice.
An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless the collection of
information displays a valid OMB control number. Books or records
relating to a collection of information must be retained if their
contents may become material in the administration of any internal
revenue law. Generally, tax returns and tax return information are
confidential, as required by 26 U.S.C. 6103.
Request for Comments: Comments submitted in response to this notice
will be summarized and/or included in the request for OMB approval. All
comments will become a matter of public record. Comments are invited
on: (a) whether the collection of information is necessary for the
proper performance of the functions of the agency, including whether
the information shall have practical utility; (b) the accuracy of the
agency's estimate of the burden of the collection of information; (c)
ways to enhance the quality, utility, and clarity of the information to
be collected; (d) ways to minimize the burden of the collection of
information on respondents, including through the use of automated
collection techniques or other forms of information technology; and (e)
estimates of capital or start-up costs and costs of operation,
maintenance, and purchase of services to provide information.
Approved: October 31, 2023.
Sara L. Covington,
IRS Tax Analyst.
[FR Doc. 2023-25410 Filed 11-16-23; 8:45 am]
BILLING CODE 4830-01-P
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