[Federal Register Volume 87, Number 249 (Thursday, December 29, 2022)]
[Proposed Rules]
[Pages 80108-80109]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-27969]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 602

[REG-146537-06]
RIN 1545-BG08


Income of Foreign Governments and International Organizations; 
Comment Period Reopening

AGENCY: Internal Revenue Service (IRS), Treasury.

[[Page 80109]]


ACTION: Notice of proposed rulemaking; reopening of comment period.

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SUMMARY: The Department of the Treasury and the IRS are reopening the 
comment period for REG-146537-06, relating to the exemption from 
taxation afforded to foreign governments under section 892.

DATES: The comment period is reopened, and additional written or 
electronic comments and requests for a public hearing must be received 
by February 27, 2023.

ADDRESSES: Commenters are strongly encouraged to submit additional 
public comments electronically. Submit electronic submissions via the 
Federal eRulemaking Portal at www.regulations.gov (indicate IRS and 
REG-146537-06) by following the online instructions for submitting 
comments. Once submitted to the Federal eRulemaking Portal, comments 
cannot be edited or withdrawn. The Department of the Treasury (the 
``Treasury Department'') and the Internal Revenue Service (the ``IRS'') 
will publish for public availability any comment submitted 
electronically, and on paper, to its public docket. Send hard copy 
submissions to: CC:PA:LPD:PR (REG-146537-06), Room 5203, Internal 
Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 
20044. Submissions may be hand delivered Monday through Friday between 
the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-146537-06), 
Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW, 
Washington, DC 20224.

FOR FURTHER INFORMATION CONTACT: Joel Deuth at (202) 317-6938; 
concerning submissions of comments or requests for a public hearing, 
Vivian Hayes at (202) 317-5306 (not toll-free numbers) or by sending an 
email to [email protected] (preferred).

SUPPLEMENTARY INFORMATION: Generally, the 2011 proposed regulations 
provide guidance relating to the exemption from taxation afforded to 
foreign governments from qualified investments in the United States 
under section 892 of the Internal Revenue Code. The Treasury Department 
and the IRS are considering finalizing the 2011 proposed regulations 
and, therefore, are reopening the comment period with respect to the 
2011 proposed regulations for 60 days. Comments that were previously 
submitted in accordance with the 2011 proposed regulations will be 
considered and do not need to be submitted again in response to this 
reopening of the comment period. The 2011 proposed regulations may be 
finalized in conjunction with finalizing the proposed regulations 
published in this issue of the Federal Register regarding the treatment 
of certain entities for purposes of the section 892 exemption that 
relate in some respects to certain provisions of the 2011 proposed 
regulations.
    Requests for Public Hearing: A public hearing will be scheduled if 
requested in writing by any person who timely submits written comments. 
Requests for a public hearing are encouraged to be made electronically. 
If a public hearing is scheduled, notice of the date and time for the 
public hearing will be published in the Federal Register. Announcement 
2020-4, 2020-17 IRB 667, provides that until further notice, public 
hearings conducted by the IRS will be held telephonically. Any 
telephonic hearing will be made accessible to people with disabilities.

Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2022-27969 Filed 12-28-22; 8:45 am]
BILLING CODE 4830-01-P