Nprm

Notice of Proposed Rulemaking
Branch Tax
INTL-934-86
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Notice of Proposed rulemak­
ing by cross-reference to temporary
regulations.
SUMMARY: This document contains
proposed Income Tax Regulations relat­
ing to the branch tax. In * * * [T.D.
8223, page 182, this Bulletin] the Inter­
nal Revenue Service is issuing temporary
regulations relating to these matters. The
text of these temporary regulations also
serves as the comment document for this
proposed rulemaking .
DATES: These regulations are proposed
to be effective for taxable years begin­
ning after December 31, 1986 , Written
comments and requests for a public hear­
ing must be delivered or mailed by
November 1, 1988.
ADDRESS: Send comments and requests
for a public hearing to Commissioner of
Internal Revenue Service, (Attention:
CC:LR:T, INTL-934-86), Washington,
DC 20224.
SUPPLEMENTARY
INFORMATION:
PAPERWORK REDUCTION ACT
The collection of information contained
in this notice of proposed rulemaking has
been submitted to the Office of Manage­
ment and Budget for review in accord­
ance with the Paperwork Reduction Act
of 1980 (44 U.S.c. 3504(h». Comments
on the collection of information should
be sent to the Office of Information and
Regulatory Affairs, Office of Manage­
ment and Budget, Washington, DC
20503, Attention: Desk Officer for Inter­
nal Revenue Service, with copies to the
Internal Revenue Service, Washington,
DC 20224, Attention: IRS Reports
Clearance Officer TR:FP.
The collection of information in this
regulation is in §§ l. 884-1T(d)(ll),
L884-2T(a)(2), 1.884-2T(b), 1.884-2T
(c)(2), 1.884-2T(d)(l), 1.884-2T(d)(4),
1.884-2T(d)(5), 1.884-4T(b)(7), 1.884­
4T(c)(l), 1.884-5T(b)(3) through (7),
1.884-5T(d)(6), aDd 1. 884-5T(t). This
information is required by the Internal

Revenue
computation
.~{ji.i~~;:i,,;,V
This information will be used in audits 0
taxpayers. The likely respondents are
business or other for-profit institutions.
Estimated total annual reporting andlor
recordkeeping burden: 20,500 hours.
The estimated annual burden per
respondent/recordkeeper varies from .5
to 10.5 hours depending on individual
circumstances, with an estimated average
of 6.5 hours.
Estimated number of respondents andl
or recordkeepers: 3000.
Estimated annual frequency of re­
sponses: Annually.
BACKGROUND
The temporary regulations published
in * * * [T.D. 8223, page 182, this Bul­
letin] add new §§ I. 884-0T through
1. 884-2T, I. 884-4T, and 1.884-5T. The
final regulations that are proposed to be
based on the temporary regulations
would amend 26 CFR Parts 1 and 602.
For the text of the temporary regulations,
see T.D. 8223 * * * [page 182, this
Bulletin].
SPECIAL ANALYSES
These proposed rules are not major
rules as defined in Executive Order
12291. Therefore, a Regulatory Impact
Analysis is not required. Although this
document is a notice of proposed rule­
making that solicits public comments,
the notice and public procedure require­
ments of 5 U .S.c. §553 do not apply
because the regulations proposed herein
are interpretative. Therefore, an initial
Regulatory Flexibility Analysis is not
reqUired by the Regulatory Flexibility
Act (5 U.S.c. Chapter 6).
COMMENTS AND

REQUEST FOR A

PUBLIC HEARING

LIST OF SUBJECTS IN
CFR §§1.861-1 through 1.997-1
Income taxes, Corporate deductions,

Aliens, Exports, DISC, Foreign invest­

ment in U. S., Foreign tax credit, FSC,

Source of income, U.S. investments

abroad.

LIST OF SUBJECTS IN

26 CFR Part 602

Reporting and Recordkeeping Re­

quirements.

Proposed amendments to the

regulations

The temporary regulations, T.n. 8223

[page 182, this Bulletin], are hereby also

proposed as final regulations under sec­

tion 884 of the Internal Revenue Code of

1986.

Lawrence B. Gibbs,
Commissioner of
Internal Revenue.
(Filed by the Office of Ihe.Federal Regisler on

August 29. 1988. 1:29 p.m., and published in

Ine issue of the Federal Register for September

2. 1988. 53 F.R. 34120)

•I

Notice of Proposed Rulemaking
Allocation and Apportionment of Inter­

est Expense and Certain Other Expenses

INTL-952-86
AGENCY: Internal Revenue Service,

Treasury.

ACTION: Notice of proposed rulemak­

ing by cross-reference to temporary reg­

ulations.

SUMMARY: This document provides

proposed' Income Tax RcplatlQDS rel~­

ing to the allocation.~~p~.i~t

of interest expense aJJacen~n other

expenses for purposes of the teXeign' taX

credit rules lUJd certais'OtbcS,r interaa­

tionalto provisioGl. In .~~ (T.D.

8228, page l~t'tbiJ:.~J,Shc inter­

Before adopting as final regulations
nal JieWCIQIC Service .is is,Ituiog.teJnporary

these proposed regulations, consideration
regUlations relating colbese ~.The

will be given to any written commepts
text of those tempohu'y regulations also

that are submitted (preferably a signed
~es as the comment File Typeapplication/pdfFile Modified2010-06-04File Created2010-06-04