[Federal Register Volume 87, Number 203 (Friday, October 21, 2022)]
[Proposed Rules]
[Page 63981]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-22891]



[[Page 63981]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-121509-00]
RIN 1545-AY54


Exclusion From Gross Income of Previously Taxed Earnings and 
Profits, and Adjustments to Basis of Stock in Controlled Foreign 
Corporations and of Other Property

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking.

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SUMMARY: This document withdraws a notice of proposed rulemaking 
published in the Federal Register on August 29, 2006. The notice of 
proposed rulemaking relates to the exclusion from gross income of 
previously taxed earnings and profits under section 959 of the Internal 
Revenue Code (the ``Code'') and related basis adjustments under section 
961 of the Code.

DATES: The proposed regulations are withdrawn on October 21, 2022.

FOR FURTHER INFORMATION CONTACT: Joshua P. Roffenbender, (202) 317-
6934, or Chadwick Rowland, (202) 317-6937 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    On August 29, 2006, the Treasury Department and the IRS issued a 
notice of proposed rulemaking relating to the exclusion from gross 
income of previously taxed earnings and profits under section 959 and 
related basis adjustments under section 961 (71 FR 51155), corrections 
to which were published in the Federal Register on December 8, 2006 (71 
FR 71116) (together, the ``2006 proposed regulations''). On December 
14, 2018, the Treasury Department and the IRS issued Notice 2019-01 
(2019-02 I.R.B. 275), which announced an intent to withdraw the 2006 
proposed regulations and issue a new notice of proposed rulemaking 
under sections 959 and 961 (the ``new proposed regulations'').
    This document withdraws the 2006 proposed regulations. Those 
proposed regulations were never finalized, never went into effect, and 
did not indicate that taxpayers could rely on them. Withdrawing the 
proposed regulations at this point will help prevent possible abuse or 
other misuse of them--such as inappropriate basis adjustments in 
certain stock acquisitions to which section 304(a)(1) applies--while 
the Treasury Department and the IRS continue to develop the new 
proposed regulations. The IRS may, where appropriate, challenge 
taxpayer positions giving rise to inappropriate results.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Withdrawal of a Notice of Proposed Rulemaking

0
Accordingly, under the authority of 26 U.S.C. 7805, the notice of 
proposed rulemaking (REG-121509-00) published in the Federal Register 
on August 29, 2006 (71 FR 51155), corrections to which were published 
in the Federal Register on December 8, 2006 (71 FR 71116), is 
withdrawn.

Douglas W. O'Donnell,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2022-22891 Filed 10-20-22; 8:45 am]
BILLING CODE 4830-01-P