[Federal Register Volume 84, Number 192 (Thursday, October 3, 2019)]
[Proposed Rules]
[Page 52835]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-21476]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-105474-18]
RIN 1545-BO59, 1545-BM69


Guidance on Passive Foreign Investment Companies; 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 under sections 1291, 1297, and 1298 of the Internal Revenue 
Code (``Code'') regarding the determination of ownership in a passive 
foreign investment company within the meaning of section 1297(a) 
(``PFIC'') and the treatment of certain income received or accrued by a 
foreign corporation and assets held by a foreign corporation for 
purposes of section 1297.

DATES: The public hearing is being held on Monday, December 9, 2019, at 
10:00 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Friday, November 22, 2019. If no 
outlines are received by November 22, 2019, the public hearing will be 
cancelled.

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-105474-18), 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-105474-18), 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-105474-18).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Josephine Firehock at (202) 317-4932 (for the PFIC Insurance Exception) 
or Jorge M. Oben at (202) 317-6934 (for general rules, including 
indirect ownership and look-through rules); concerning submissions of 
comments, the hearing and/or to be placed on the building access list 
to attend the hearing, Regina Johnson at (202) 317-6901 (not toll-free 
numbers), [email protected].

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking (REG-105474-18) that was published in the 
Federal Register on Thursday, July 11, 2019 (84 FR 33120).
    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 September 9, 2019, must submit an outline of the topics to 
be addressed and the amount of time to be devoted to each topic by 
Friday, November 22, 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 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.

Crystal Pemberton,
Senior Federal Liaison, Publications and Regulations Branch, Legal 
Processing Division, Associate Chief Counsel, (Procedure and 
Administration).
[FR Doc. 2019-21476 Filed 10-2-19; 8:45 am]
 BILLING CODE 4830-01-P