[Federal Register Volume 84, Number 55 (Thursday, March 21, 2019)]
[Notices]
[Page 10577]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-05390]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Notice 2006-46

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: The Internal Revenue Service (IRS), 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 information collections, as required by the Paperwork Reduction Act 
of 1995. The IRS is soliciting comments concerning Treatment of 
distributions by foreign corporations and Coordination with 
nonrecognition provisions.

DATES: Written comments should be received on or before May 20, 2019 to 
be assured of consideration.

ADDRESSES: Direct all written comments to Laurie Brimmer, Internal 
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 
20224.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of this notice should be directed to Martha R. Brinson, at (202) 
317-5753, or at Internal Revenue Service, Room 6526, 1111 Constitution 
Avenue NW, Washington, DC 20224, or through the internet at 
[email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Announcement of Rules to be Included in Final Regulations 
concerning Treatment of distributions by foreign corporations and 
Coordination with nonrecognition provisions under Section 897(d) and 
(e) of the Internal Revenue Code.
    OMB Number: 1545-2017.
    Notice Number: Notice 2006-46.
    Abstract: This notice announces that the IRS and Treasury 
Department will issue final regulations under section 897(d) and (e) of 
the Internal Revenue Code that will revise the rules under Temp. Treas. 
Reg. Sec.  [thinsp]1.897-5T, Notice 89-85, and Temp. Treas. Reg. Sec.  
[thinsp]1.897-6T to take into account statutory mergers and 
consolidations under foreign or possessions law which may now qualify 
for nonrecognition treatment under section 368(a)(1)(A). The specific 
collections of information are contained in Temp. Treas. Reg. 
Sec. Sec.  [thinsp]1.897-5T(c)(4)(ii)(C) and 1.897-6T(b)(1). These 
reporting requirements notify the IRS of the transfer and enable it to 
verify that the transferor qualifies for nonrecognition and that the 
transferee will be subject to U.S. tax on a subsequent disposition of 
the U.S. real property interest.
    Current Actions: There are no changes being made to the notice at 
this time.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Business or other-for-profit organizations.
    Estimated Number of Respondents: 500.
    Estimated Time per Respondent: 1 hour.
    Estimated Total Annual Reporting Burden Hours: 500.
    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. 
Comments will be 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 has 
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 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: March 18, 2019.
Laurie Brimmer,
Senior Tax Analyst.
[FR Doc. 2019-05390 Filed 3-20-19; 8:45 am]
 BILLING CODE 4830-01-P