[Federal Register Volume 89, Number 69 (Tuesday, April 9, 2024)]
[Notices]
[Pages 24892-24893]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-07452]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Special Rules and 
Certificate of Partner-Level Items To Reduce Withholding

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 
special rules and certificate of partner-level items to reduce 
withholding.

DATES: Written comments should be received on or before June 10, 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]. Include OMB control number 
1545-1934 or Special Rules and Certificate of Partner-Level Items to 
Reduce Section 1446 Withholding.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the regulation or form should be directed to Kerry Dennis at 
(202) 317-5751, or at Internal Revenue Service, Room 6526, 1111 
Constitution Avenue NW, Washington, DC 20224, or through the internet, 
at [email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Special Rules and Certificate of Partner-Level Items to 
Reduce Section 1446 Withholding.
    OMB Number: 1545-1934.
    Regulation and Form Number: T.D. 9394 and Form 8404-C.
    Abstract: T.D. 9394 contains final regulations regarding when a 
partnership may consider certain deductions and losses of a foreign 
partner to reduce or eliminate the partnership's obligation to pay 
withholding tax under section 1446 on effectively connected taxable 
income allocable under section 704 to such partner. Form 8804-C is used 
by a foreign partner that voluntary submit to the partnership if it 
chooses to provide a certification that could reduce or eliminate the 
partnership's withholding tax obligation under section 1446 (1446 tax) 
on the partner's allocable share of effectively connected income (ECTI) 
from the partnership.
    Current Actions: There is no change to the paperwork burden 
previously approved by OMB.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Businesses and other for-profit organizations, 
Individuals or Households, and Not-for-Profit Organizations.

Form 8804-C

    Estimated Number of Respondents: 1,000.
    Estimated Time per Response: 18.7 hours.
    Estimated Total Annual Burden Hours: 18,700 hours.

TD 9394

    Estimated Number of Respondents: 1.
    Estimated Time per Response: 1 hours.
    Estimated Total Annual Burden Hours: 1 hour.
    Total Number of Respondents: 1,001.
    Total Estimated Annual Burden Hours: 18,701.
    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

[[Page 24893]]

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: April 3, 2024.
Kerry L. Dennis,
Tax Analyst.
[FR Doc. 2024-07452 Filed 4-8-24; 8:45 am]
BILLING CODE 4830-01-P