[Federal Register Volume 84, Number 46 (Friday, March 8, 2019)]
[Proposed Rules]
[Pages 8488-8489]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-04203]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[REG-104352-18]
RIN 1545-BO53


Rules Regarding Certain Hybrid Arrangements; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Proposed rule; notice of hearing.

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SUMMARY: This document provides a notice of public hearing on proposed 
regulations to implement sections 245A(e) and 267A of the Internal 
Revenue Code (Code) regarding hybrid dividends and certain amounts paid 
or accrued in hybrid transactions or with hybrid entities, and to 
provide rules under sections 1503(d) and 7701 of the Code to prevent 
the same deduction from being claimed under the tax laws of both the 
United States and a foreign country.

DATES: The public hearing is being held on Wednesday, March 20, 2019, 
at 10 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Friday, March 15, 2019.

ADDRESSES: The public hearing is being held in the IRS Auditorium, 
Internal Revenue Service Building, 1111 Constitution Avenue NW, 
Washington, DC 20224. Due to building security procedures, visitors 
must enter at the Constitution Avenue entrance. In addition, all 
visitors must present a valid photo identification to enter the 
building.
    Send Submissions to CC:PA:LPD:PR (REG-104352-18), Room 5205, 
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Submissions may be hand-delivered Monday through 
Friday to CC:PA:LPD:PR (REG-104352-18), Couriers Desk, Internal Revenue 
Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent 
electronically via the Federal eRulemaking Portal at 
www.regulations.gov (IRS REG-104352-18).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
contact Tracy Villecco at (202) 317-3800; concerning submissions of 
comments, the hearing and/or to be placed on the building access list 
to attend the hearing, Regina L. Johnson at (202) 317-6901 (not toll 
free numbers) or [email protected].

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking (REG-104352-18) that was published in the 
Federal Register on Friday, December 28, 2018 (83 FR 67612).
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments at the hearing that submitted written 
comments by February 26, 2019, must submit an outline of the topics to 
be addressed and the amount of time to be devoted to each topic by 
Friday, March 15, 2019.
    A period of 10 minutes is allotted to each person for presenting 
oral comments. After the deadline for receiving outlines has passed, 
the IRS will prepare an agenda containing the schedule of speakers. 
Copies of the agenda will be made available, free of charge, at the 
hearing or by contacting the Publications and Regulations Branch at 
(202) 317-6901(not a toll-free number).
    Because of access restrictions, the IRS will not admit visitors 
beyond the immediate entrance area more than 30 minutes before the 
hearing starts. For

[[Page 8489]]

information about having your name placed on the building access list 
to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section 
of this document.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2019-04203 Filed 3-7-19; 8:45 am]
 BILLING CODE 4830-01-P