United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2017_register executive 2017-11-30 article Proposed Rules D09002ee1c7ef3dda D09002ee1c7ef3e2f United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules addressing how certain international rules operate in the context of the centralized partnership audit regime, including rules relating to the withholding of tax on foreign persons, withholding of tax to enforce reporting on certain foreign accounts, and the treatment of creditable foreign tax expenditures of a partnership. 82 FR 56765 https://www.govinfo.gov/app/details/FR-2017-11-30/2017-25740 2017-25740 fr30no17-13 RIN 1545-BN95 4830-01-P REG-119337-17 https://www.govinfo.gov/app/details/FR-2017-11-30/2017-25740 https://www.govinfo.gov/content/pkg/FR-2017-11-30/html/2017-25740.htm https://www.govinfo.gov/content/pkg/FR-2017-11-30/pdf/2017-25740.pdf Employment Taxes Estate Taxes Excise Taxes Gift Taxes Income Taxes Penalties Reporting and Recordkeeping Requirements 15 p. 56765 56779 82 FR 56765 Title 26 Part 301 26 CFR Part 301 RIN 1545-BN95 Centralized Partnership Audit Regime: International Tax Rules; Federal Register Vol. 82, Issue PRORULE 2017-25740 DEPARTMENT OF THE TREASURY Internal Revenue Service 2018-01-29 REG-119337-17 4830-01-P 2017-25740 Notice of proposed rulemaking.

This document contains proposed regulations implementing section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules addressing how certain international rules operate in the context of the centralized partnership audit regime, including rules relating to the withholding of tax on foreign persons, withholding of tax to enforce reporting on certain foreign accounts, and the treatment of creditable foreign tax expenditures of a partnership.

Written or electronic comments and requests for a public hearing must be received by January 29, 2018. Concerning the proposed regulations relating to creditable foreign tax expenditures, Larry R. Pounders, Jr., of the Office of Associate Chief Counsel (International), (202) 317-5465; concerning the proposed regulations relating to chapters 3 and 4 of subtitle A of the Internal Revenue Code (other than section 1446), Subin Seth of the Office of Associate Chief Counsel (International), (202) 317-5003; concerning the proposed regulations relating to section 1446, Ronald M. Gootzeit of the Office of Associate Chief Counsel (International), (202) 317-4953; concerning the submission of comments or a request for a public hearing, Regina Johnson, (202) 317-6901 (not toll-free numbers). Employment Taxes Estate Taxes Excise Taxes Gift Taxes Income Taxes Penalties Reporting and Recordkeeping Requirements Centralized Partnership Audit Regime: International Tax Rules , www.irs.gov www.regulations.gov Vol. 82, no. 229 Office of the Federal Register, National Archives and Records Administration 2017-11-30 continuing daily deposited born digital 166 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2017-11-30 P0b002ee197a5108a 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr30no17 https://www.govinfo.gov/app/details/FR-2017-11-30 https://www.govinfo.gov/content/pkg/FR-2017-11-30/pdf/FR-2017-11-30.pdf https://www.govinfo.gov/content/pkg/FR-2017-11-30/xml/FR-2017-11-30.xml fdlp 56703 56858 DGPO 2017-11-30 2024-06-01 FR-2017-11-30 machine generated eng FR FR-2017-11-30 82 229