[Federal Register Volume 79, Number 166 (Wednesday, August 27, 2014)]
[Notices]
[Page 51228]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-20344]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

[Notice 2005-38]


Proposed Collection; Comment Request for Regulation Project

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: The Department of the Treasury, 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 proposed and/or continuing information collections, as required by 
the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 
3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning 
Notice-2005-38, Limitations on Dividends Received Deduction and Other 
Guidance.

DATES: Written comments should be received on or before October 27, 
2014 to be assured of consideration.

ADDRESSES: Direct all written comments to R. Joseph Durbala, Internal 
Revenue Service, Room 6129, 1111 Constitution Avenue NW., Washington, 
DC 20224.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the regulation should be directed to Sara Covington, at 
Internal Revenue Service, Room 6129, 1111 Constitution Avenue NW., 
Washington, DC 20224, or through the internet, at 
[email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Limitations on Dividends Received Deduction and Other 
Guidance.
    OMB Number: 1545-1943.
    Regulation Project Number: Notice-2005-38.
    Abstract: This document provides guidance under new section 965, 
which was enacted by the American Jobs Creation Act of 2004 (Pub. L. 
108-357). In general, and subject to limitations and conditions, 
section 975(a) provides that a corporation that is a U.S. shareholder 
of a controlled foreign corporation (CFC) may elect, for one taxable 
year, an 85 percent dividends received deduction (DRD) with respect to 
certain cash dividends it receives from its CFCs. This document 
addresses limitations imposed on the maximum amount of section 965(a) 
DRD under section 965(b)(1) (under which the maximum amount of an 
eligible dividend is the greatest of $500 million, or earnings 
permanently reinvested outside the United States), section 965(b)(2) 
(regarding certain base-period repatriations), section 965(b)(3) 
(regarding certain increases in related party indebtedness), and 
certain miscellaneous limitations (related to the foreign tax credit).
    Current Actions: There is no change to this notice.
    Type of Review: Extension of OMB approval.
    Affected Public: Business or other for-profit organizations.
    Estimated Number of Respondents: 25,000.
    Estimated Time per Respondent: 50 hours.
    Estimated Total Annual Burden Hours: 1,250,000.
    The following paragraph applies to all of 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 as long as 
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: August 20, 2014.
R. Joseph Durbala,
IRS Supervisory Tax Analyst.
[FR Doc. 2014-20344 Filed 8-26-14; 8:45 am]
BILLING CODE 4830-01-P