[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