[Federal Register Volume 88, Number 25 (Tuesday, February 7, 2023)]
[Proposed Rules]
[Page 7903]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-02574]



[[Page 7903]]

=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-112096-22]
RIN 1545-BQ46


Guidance Related to the Foreign Tax Credit; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; notice of hearing.

-----------------------------------------------------------------------

SUMMARY: This document provides a notice of public hearing on proposed 
regulations relating to the foreign tax credit, including guidance with 
respect to the reattribution asset rule for purposes of allocating and 
apportioning foreign taxes, the cost recovery requirement, and the 
attribution rule for withholding tax on royalty payments.

DATES: The public hearing is being held on Wednesday, February 15, 
2023, at 10 a.m. EDT. The IRS must receive speakers' outlines of the 
topics to be discussed at the public hearing by Friday, February 10, 
2023.

ADDRESSES: The public hearing is being held by teleconference. 
Individuals that have submitted an outline of testimony and 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-112096-22] and the word TESTIFY. For example, 
the subject line may say: Request to TESTIFY at Hearing for REG-112096-
22. The email must include the name(s) of the speaker(s) and title(s) 
only. No outlines will be accepted by email. Send outline submissions 
electronically via the Federal eRulemaking Portal at 
www.regulations.gov (IRS REG-112096-22). The email must be received by 
February 10, 2023.

FOR FURTHER INFORMATION CONTACT: Concerning Sec. Sec.  1.901-2 and 
1.903-1, Teisha Ruggiero, (646) 259-8116, Sec.  1.861-20, Suzanne 
Walsh, (202) 317-4908; concerning submissions of comments, the hearing, 
and the access code to attend the hearing by teleconferencing, Vivian 
Hayes at (202) 317-5306 (not toll-free numbers) or 
[email protected]. If emailing, please include Attend, Testify, or 
Agenda Request and [REG-112096-22] in the email subject line.

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking REG-112096-22 that was published in the 
Federal Register on Tuesday, November 22, 2022, 87 FR 71271.
    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 
previously submitted written comments by January 23, 2023, must submit 
an outline on the topics to be addressed and the amount of time to be 
devoted to each topic by February 10, 2023. A period of 10 minutes is 
allotted to each person for presenting oral comments.
    After receiving outlines, the IRS will prepare an agenda containing 
the schedule of speakers. The agenda will be available via Federal 
eRulemaking Portal (www.Regulations.gov) under the title of Supporting 
& Related Material by February 12, 2023. The public hearing agenda will 
contain the telephone number and access code.
    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-112096-22] and the 
word ATTEND. For example, the subject line may say: Request to ATTEND 
Hearing for REG-112096-22. The email requesting to attend the public 
hearing must be received by 5 p.m. EDT 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) 317-5306 (not a toll-free number) by Friday, February 10, 
2023.
    Any questions regarding speaking at or attending a public hearing 
may also be emailed to [email protected].

Oluwafunmilayo A. Taylor,
Branch Chief, Publications and Regulations Branch, Legal Processing 
Division, Associate Chief Counsel (Procedure and Administration).
[FR Doc. 2023-02574 Filed 2-6-23; 8:45 am]
BILLING CODE 4830-01-P