[Federal Register Volume 73, Number 37 (Monday, February 25, 2008)]
[Proposed Rules]
[Pages 9971-9972]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 08-823]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-107592-00]
RIN 1545-BA11


Consolidated Returns; Intercompany Obligations

AGENCY: Internal Revenue Service (IRS), Treasury.

[[Page 9972]]


ACTION: Partial withdrawal of notice of proposed rulemaking.

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SUMMARY: This document withdraws a portion of a notice of proposed 
rulemaking (REG-107592-00) published in the Federal Register on 
September 28, 2007 (72 FR 55139). The withdrawn portion relates to the 
treatment of transactions involving the provision of insurance between 
members of a consolidated group.

FOR FURTHER INFORMATION CONTACT: Frances L. Kelly, (202) 622-7770 (not 
a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    On September 28, 2007, the IRS and the Treasury Department 
published a notice of proposed rulemaking (REG-107592-00) in the 
Federal Register (72 FR 55139) which proposed to amend Sec.  1.1502-
13(g) (regarding the treatment of transactions involving obligations 
between members of a consolidated group) and to add Sec.  1.1502-
13(e)(2)(ii)(C) (regarding the treatment of certain transactions 
involving the provision of insurance between members of a consolidated 
group).
    Under proposed Sec.  1.1502-13(e)(2)(ii)(C), certain intercompany 
insurance transactions would be taken into account on a single entity 
basis. Written comments were received with respect to proposed Sec.  
1.1502-13(e)(2)(ii)(C). After consideration of these comments, the IRS 
and the Treasury Department have decided to withdraw proposed Sec.  
1.1502-13(e)(2)(ii)(C). However, the IRS and the Treasury Department 
continue to study whether revisions to the rules for intercompany 
transactions are necessary to clearly reflect the taxable income of 
consolidated groups.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Partial Withdrawal of a Notice of Proposed Rulemaking

    Accordingly, under the authority of 26 U.S.C. 7805 and 26 U.S.C. 
1502, Sec.  1.1502-13(e)(2)(ii)(C) of the notice of proposed rulemaking 
(REG-107592-00) that was published in the Federal Register on September 
28, 2007 (72 FR 55139) is withdrawn.

Linda E. Stiff,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 08-823 Filed 2-20-08; 8:48 am]
BILLING CODE 4830-01-P