[Federal Register Volume 85, Number 85 (Friday, May 1, 2020)]
[Proposed Rules]
[Page 25378]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08842]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-105495-19]
RIN 1545-BP21


Guidance Related to the Allocation and Apportionment of 
Deductions and Foreign Taxes, Financial Services Income, Foreign Tax 
Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), 
and Consolidated Groups; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Proposed rule; notification of hearing.

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SUMMARY: This document provides a notice of public hearing on proposed 
regulations that provide guidance relating to the allocation and 
apportionment of deductions and creditable foreign taxes, the 
definition of financial services income, foreign tax redeterminations, 
availability of foreign tax credits under the transition tax, and the 
application of the foreign tax credit limitation to consolidated 
groups.

DATES: The public hearing is being held on Wednesday, May 20, 2020, at 
10:00 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Monday, May 11, 2020. If no outlines 
are received by May 11, 2020, the public hearing will be cancelled.

ADDRESSES: The public hearing is being held by teleconference. 
Individuals who want to testify (by telephone) at the public hearing 
must send an email to [email protected] to receive the telephone 
number and access code for the hearing. The subject line of the email 
must contain the regulation number REG-105495-19 and the word TESTIFY. 
For example, the subject line may say: Request to TESTIFY at Hearing 
for REG-105495-19. The email should also include a copy of the 
speaker's public comments and outline of topics. The email must be 
received by May 11, 2020.
    Individuals who want to attend (by telephone) the public hearing 
must also send an email to [email protected] to receive the 
telephone number and access code for the hearing. The subject line of 
the email must contain the regulation number REG-105495-19 and the word 
ATTEND. For example, the subject line may say: Request to ATTEND 
Hearing for REG-105495-19. The email requesting to attend the public 
hearing must be received by 5:00 p.m. two (2) business days before the 
date that the hearing is scheduled.
    The telephonic hearing will be made accessible to people with 
disabilities. To request special assistance during the telephonic 
hearing please contact the Publications and Regulations Branch of the 
Office of Associate Chief Counsel (Procedure and Administration) by 
sending an email to [email protected] (preferred) or by telephone 
at (202) 317-5177 (not a toll-free number) at least three (3) days 
prior to the date that the telephonic hearing is scheduled.
    Any questions regarding speaking at or attending a public hearing 
may also be emailed to [email protected].
    Send outline submissions electronically via the Federal eRulemaking 
Portal at www.regulations.gov (IRS REG-105495-19).

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Jeffrey Cowan at (202) 317- 4924; concerning submissions of comments, 
the hearing and/access code to attend the hearing by teleconferencing, 
Regina Johnson at (202) 317-5177 (not toll-free numbers) or 
[email protected].

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking REG-105495-19 that was published in the 
Federal Register on December 17, 2019, 84 FR 69124.
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments telephonically at the hearing that 
submitted written comments by February 18, 2020, must submit an outline 
of the topics to be addressed and the amount of time to be devoted to 
each topic by May 11, 2020.
    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, on Regulations.gov, search 
IRS and REG-105495-19, or by emailing your request to 
[email protected].
    Please put ``REG-105495-19 Agenda Request'' in the subject line of 
the email.

Martin V. Franks,
Branch Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2020-08842 Filed 4-30-20; 8:45 am]
BILLING CODE 4830-01-P