Notice2025-08326
Agency Information Collection Activities; Comment Request for Conduit Arrangements Recordkeeping Requirements
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
May 13, 2025
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 conduit arrangements recordkeeping requirements.
Full Text
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<title>Federal Register, Volume 90 Issue 91 (Tuesday, May 13, 2025)</title>
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[Federal Register Volume 90, Number 91 (Tuesday, May 13, 2025)]
[Notices]
[Page 20349]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-08326]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
Agency Information Collection Activities; Comment Request for
Conduit Arrangements Recordkeeping Requirements
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
conduit arrangements recordkeeping requirements.
DATES: Written comments should be received on or before July 14, 2025
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#7d0d0f1c531e1210101813090e3d140f0e531a120b"><span class="__cf_email__" data-cfemail="453537246b262a2828202b3136052c37366b222a33">[email protected]</span></a>. Include OMB control number
1545-1440 or Conduit Arrangements Recordkeeping, in the subject line of
the message.
FOR FURTHER INFORMATION CONTACT: Requests for additional information or
copies of the form should be directed to LaNita Van Dyke (202) 317-
6009, or at Internal Revenue Service, Room 6526, 1111 Constitution
Avenue NW, Washington, DC 20224, or through the internet, at
<a href="/cdn-cgi/l/email-protection#5519343b3c21347b03343b112c3e30153c27267b323a23"><span class="__cf_email__" data-cfemail="a2eec3cccbd6c38cf4c3cce6dbc9c7e2cbd0d18cc5cdd4">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Title: Conduit Arrangements Recordkeeping Requirements.
OMB Number: 1545-1440.
Regulation Number: T.D. 8611.
Abstract: Treasury Decision (TD) 8611 provides rules that permit
the district director to recharacterize a financing arrangement as a
conduit arrangement. The recharacterization will affect the amount of
U.S. withholding tax due on financing transactions that are part of the
financing arrangement. This TD requires parties to the financing
arrangement maintain specific records about the transaction and its
circumstances, as detailed in 26 CFR 1.881-4(c). Additionally, each
Section 6038 or 6038A party to the financing arrangement must comply
with the recordkeeping requirements of 26 CFR 1.6038A-3 with respect to
records that are relevant to the determination under Sec. 1.881-3 of
the regulations.
Current Actions: There is no change in the paperwork burden
previously approved by OMB.
Type of Review: Extension of a currently approved collection.
Affected Public: Business or other for-profit organizations.
Estimated Number of Respondents: 1,000.
Estimated Time per Respondent: 10 minutes.
Estimated Total Annual Burden Hours: 10,000 hours.
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: May 6, 2025.
Molly J. Stasko,
Senior Tax Analyst.
[FR Doc. 2025-08326 Filed 5-12-25; 8:45 am]
BILLING CODE 4830-01-P
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