[Federal Register Volume 90, Number 105 (Tuesday, June 3, 2025)]
[Proposed Rules]
[Pages 23494-23495]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-09981]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-107420-24]
RIN 1545-BR21
Source of Income From Cloud Transactions; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; notice of hearing.
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SUMMARY: This document provides a notice of public hearing on proposed
rules for determining the source of income from cloud transactions for
purposes of the international provisions of the Internal Revenue Code.
DATES: The public hearing on these proposed rules has been scheduled
for Thursday, July 17, 2025, at 10:00 a.m. Eastern Time (ET). The IRS
must receive speakers' outlines of the topics to be discussed at the
public hearing by June 17, 2025. If no outlines are received by June
17, 2025, the public hearing will be cancelled.
ADDRESSES: The public hearing is being held in the Auditorium, at the
Internal Revenue Service Building, 1111 Constitution Avenue NW,
Washington, DC. Due to security procedures, visitors must enter at the
Constitution Avenue entrance. In addition, all visitors must present a
valid photo identification to enter the building. Because of access
restrictions, visitors will not be admitted beyond the immediate
entrance area more than 30 minutes before the hearing starts.
Participants may alternatively attend the public hearing by telephone.
Send submissions to CC:PA:01:PR (REG-107420-24), Room 5205,
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand delivered Monday through
Friday to CC:PA:01:PR (REG-107420-24), Couriers Desk, Internal Revenue
Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent
electronically via the Federal eRulemaking Portal at
www.regulations.gov (REG-107420-24).
FOR FURTHER INFORMATION CONTACT: Concerning the proposed rules, Jacob
Nava at (202) 317-4432, (not a toll-free number); concerning
submissions of requests to testify, the hearing and/or to be placed on
the building access list to attend the public hearing, contact the
Publications and Regulations Section of the Office of Associate Chief
Counsel (Procedure and Administration) by email at
[email protected] (preferred) or by telephone at (202) 317-6901
(not a toll free number).
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking (REG-107420-24) that was published in the
Federal Register on Tuesday, January 14, 2025 (90 FR 3075).
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments at the hearing must submit an outline of
the topics to be discussed and the time to be devoted to each topic by
June 17, 2025.
A period of 10 minutes will be allotted to each person for making
comments. An agenda showing the scheduling of the speakers will be
prepared after the deadline for receiving outlines has passed. Copies
of the agenda will be available free of charge at the hearing and via
the Federal eRulemaking Portal (www.regulations.gov) under the title of
Supporting & Related Material. If no outline of the topics to be
discussed at the hearing is received by June 17, 2025, the public
hearing will be cancelled. If the public hearing is cancelled, a notice
of cancellation of the public hearing will be published in the Federal
Register.
Individuals who want to testify in person at the public hearing
must send an email to [email protected] to have your name added to
the building access list. The subject line of the email must contain
the regulation number REG-107420-24 and the language TESTIFY In Person.
For example, the subject line may say: Request to TESTIFY In Person at
Hearing for REG-107420-24. Submit of an outline of testimony as
prescribed in the ADDRESSES paragraph of this document.
Individuals who 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-107420-24 and the language
TESTIFY Telephonically. For example, the subject line may say: Request
to TESTIFY Telephonically at Hearing for REG-107420-24. Submit of an
outline of testimony as prescribed in
[[Page 23495]]
the ADDRESSES paragraph of this document.
Individuals who want to attend the public hearing in person without
testifying must also send an email to [email protected] to have
your name added to the building access list. The subject line of the
email must contain the regulation number REG-107420-24 and the language
ATTEND In Person. For example, the subject line may say: Request to
ATTEND Hearing In Person for REG-107420-24. Requests to attend the
public hearing must be received by July 16, 2025, 5:00 p.m. ET.
Individuals who want to attend the public hearing by telephone
without testifying 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-
107420-24 and the language ATTEND Hearing Telephonically. For example,
the subject line may say: Request to ATTEND Hearing Telephonically for
REG-107420-24. Requests to attend the public hearing must be received
by July 16, 2025, 5:00 p.m. ET.
Hearings will be made accessible to people with disabilities. To
request special assistance during a hearing please contact the
Publications and Regulations Section of the Office of Associate Chief
Counsel (Procedure and Administration) by sending an email to
[email protected] (preferred) or by telephone at (202) 317-6901
(not a toll-free number) by July 10, 2025.
Any questions regarding speaking at or attending a public hearing
may also be emailed to [email protected].
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations Section, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2025-09981 Filed 6-2-25; 8:45 am]
BILLING CODE 4830-01-P