[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.

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[[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]
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