Foreign Tax Credit: Notification of Foreign Tax Redeterminations

ICR 202011-1545-010

OMB: 1545-1056

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2020-12-18
Supplementary Document
2017-03-14
ICR Details
1545-1056 202011-1545-010
Received in OIRA 201703-1545-008
TREAS/IRS
Foreign Tax Credit: Notification of Foreign Tax Redeterminations
Revision of a currently approved collection   No
Regular 12/30/2020
  Requested Previously Approved
36 Months From Approved 01/31/2021
13,500 13,000
56,065 54,000
0 0

Section 905(c) requires that a taxpayer notify the Internal Revenue Service of a change in the taxpayer's foreign income tax liability that may affect its foreign tax credit. Regulation section 1.905-4T provides rules concerning the time, manner, and contents of such notification. Should the taxpayer fail to notify the IRS, penalties under section 6689 may be imposed. Respondents are U.S. taxpayers that claim a foreign tax credit under section 901, 902, or 960.

PL: Pub.L. 105 - 34 1102(a), 1102(a)(2) Name of Law: Taxpayer Relief Act of 1997
   PL: Pub.L. 108 - 357 480(a) Name of Law: American Jobs Creation Act of 2004
   US Code: 26 USC 905(c) Name of Law: Adjustments to accrued taxes
  
None

1545-BP70 Proposed rulemaking 85 FR 72078 11/12/2020

No

1
IC Title Form No. Form Name
REG-209020-86 (NPRM & Temporary) - Foreign Tax Credit: Notification of Foreign Tax Redeterminations

  Total Request Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 13,500 13,000 0 500 0 0
Annual Time Burden (Hours) 56,065 54,000 0 2,065 0 0
Annual Cost Burden (Dollars) 0 0 0 0 0 0
Yes
Changing Regulations
No
The burden for OMB Control Number 1545-1056 has been updated to reflect the issuance of TD 9922. Final regulations at §1.905-4, consistent with the former temporary regulations, provide an exception to the general notification rule that allows Large Business and International (LBI) taxpayers to notify the IRS of an FTR that occurs prior to an audit, and requires LBI taxpayers to notify the IRS of an FTR that occurs during the first 180 days of the audit, by providing the written statement to the examiner in lieu of filing an amended return. This change results in a response and respondent increase of 500 (13,000 to 13,500) and overall annual time burden increase of 2,065 hours (54,000 to 56,065).

$0
No
    Yes
    No
No
No
No
No
Jeffrey Cowan 202 622-3860

  No

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
 
 
 
 
 
 
 
    (i) Why the information is being collected;
    (ii) Use of information;
    (iii) Burden estimate;
    (iv) Nature of response (voluntary, required for a benefit, or mandatory);
    (v) Nature and extent of confidentiality; and
    (vi) Need to display currently valid OMB control number;
 
 
 
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
12/30/2020


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