[Federal Register Volume 84, Number 105 (Friday, May 31, 2019)]
[Notices]
[Pages 25335-25336]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-11379]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
Proposed Collection; Comment Request for TD 9452
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice and request for comments.
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SUMMARY: The Internal Revenue Service, 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 final regulation TD
9452, Application of Separate Limitations to Dividends from
Noncontrolled Section 902 Corporations.
DATES: Written comments should be received on or before July 30, 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 the regulation should be directed to Sara Covington, (202)
317-6038, at Internal Revenue Service, Room 6526, 1111 Constitution
Avenue NW, Washington, DC 20224, or through the internet at
[email protected].
SUPPLEMENTARY INFORMATION:
Title: Application of Separate Limitations to Dividends from
Noncontrolled Section 902 Corporations.
OMB Number: 1545-2014.
Regulation Project Number: TD 9452.
Abstract: The regulations require a collection of information in
order for a taxpayer to make certain tax elections. The American Jobs
Creation Act of 2004 amended the foreign tax credit treatment of
dividends from noncontrolled section 902 corporations effective for
post-2002 tax years, and the Gulf Opportunity Zone Act of 2005
permitted taxpayers to elect to defer the effective date of these
amendments until post-2004 tax years (GOZA election). Treas. Reg. Sec.
1.904-7(f)(9)(ii)(C) requires a taxpayer making the GOZA election to
attach a statement to such effect to its next tax return for which the
due date (with extensions) is more than 90 days after April 25, 2006.
Treas. Reg. Sec. 1.964-1(c)(3) requires certain shareholders making
tax elections (section 964 elections) on behalf of a controlled foreign
corporation or noncontrolled section 902 corporation to sign a jointly
executed consent (that is retained by one designated shareholder) and
to attach a statement to their tax returns for the election year.
Current Actions: There is no change in the paperwork burden
previously approved by OMB.
Type of Review: Extension of a currently approved collection.
Affected Public: Individuals and Households, Businesses and other
for-profit organizations.
Estimated Number of Respondents: 50.
Estimated Time per Respondent: 30 minutes.
Estimated Total Annual Burden Hours: 25.
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,
[[Page 25336]]
maintenance, and purchase of services to provide information.
Approved: May 28, 2019.
Laurie Brimmer,
Senior Tax Analyst.
[FR Doc. 2019-11379 Filed 5-30-19; 8:45 am]
BILLING CODE 4830-01-P