[Federal Register Volume 88, Number 221 (Friday, November 17, 2023)]
[Notices]
[Page 80388]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-25410]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Certain Transfers of 
Domestic Stock or Securities by U.S. Persons to Foreign Corporations

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: The Internal Revenue Service, as part of its continuing effort 
to reduce paperwork and respondent burden, invites the general public 
and other Federal agencies to take this opportunity to comment on 
continuing information collections, as required by the Paperwork 
Reduction Act of 1995. The IRS is soliciting comments concerning 
certain transfers of domestic stock or securities by U.S. persons to 
foreign corporations.

DATES: Written comments should be received on or before January 16, 
2024 to be assured of consideration.

ADDRESSES: Direct all written comments to Andres Garcia, Internal 
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 
20224 or by email to [email protected]. Please include the OMB 
Control Number 1545-1478 or TD 8702 in the Subject line.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the form should be directed to Kerry Dennis, at (202) 317-
5744 or Internal Revenue Service, Room 6526, 1111 Constitution Avenue 
NW, Washington, DC 20224, or through the internet, at 
[email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Certain Transfers of Domestic Stock or Securities by U.S. 
Persons to Foreign Corporations.
    OMB Number: 1545-1478.
    Regulation Project Number: TD 8702.
    Abstract: The regulation relates to certain transfers of stock or 
securities of domestic corporations pursuant to the corporate 
organization, reorganization, or liquidation provisions of the internal 
Revenue Code. Transfers of stock or securities by U.S. persons in tax-
free transactions are treated as taxable transactions when the acquirer 
is a foreign corporation, unless an exception applies under Code 
section 367(a). This regulation provides that no U.S. person will 
qualify for an exception unless the U.S. target company complies with 
certain reporting requirements.
    Current Actions: There are no changes being made to the regulations 
at this time.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Business or other for-profit organizations.
    Estimated Number of Respondents: 100.
    Estimated Time per Respondent: 10 minutes.
    Estimated Total Annual Burden Hours: 1,000.
    The following paragraph applies to all the collections of 
information covered by this notice.
    An agency may not conduct or sponsor, and a person is not required 
to respond to, a collection of information unless the collection of 
information displays a valid OMB control number. Books or records 
relating to a collection of information must be retained if their 
contents may become material in the administration of any internal 
revenue law. Generally, tax returns and tax return information are 
confidential, as required by 26 U.S.C. 6103.
    Request for Comments: Comments submitted in response to this notice 
will be summarized and/or included in the request for OMB approval. All 
comments will become a matter of public record. Comments are invited 
on: (a) whether the collection of information is necessary for the 
proper performance of the functions of the agency, including whether 
the information shall have practical utility; (b) the accuracy of the 
agency's estimate of the burden of the collection of information; (c) 
ways to enhance the quality, utility, and clarity of the information to 
be collected; (d) ways to minimize the burden of the collection of 
information on respondents, including through the use of automated 
collection techniques or other forms of information technology; and (e) 
estimates of capital or start-up costs and costs of operation, 
maintenance, and purchase of services to provide information.

    Approved: October 31, 2023.
Sara L. Covington,
IRS Tax Analyst.
[FR Doc. 2023-25410 Filed 11-16-23; 8:45 am]
BILLING CODE 4830-01-P