[Federal Register Volume 86, Number 38 (Monday, March 1, 2021)]
[Notices]
[Page 12076]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-04109]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Regulation Project

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 
adopted ``aggregate treatment'' with respect to income inclusion 
amounts arising from section 951A (the global intangible low tax income 
inclusion or GILTI) for partnerships.

DATES: Written comments should be received on or before April 30, 2021 
to be assured of consideration.

ADDRESSES: Direct all written comments to Kinna Brewington, Internal 
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 
20224.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the form should be directed to Paul Adams, at (737) 800-6149 
or Internal Revenue Service, Room 6526, 1111 Constitution Avenue NW, 
Washington, DC 20224, or through the internet, at <a href="/cdn-cgi/l/email-protection#ca9aabbfa6e48ee48baeaba7b98aa3b8b9e4ada5bc"><span class="__cf_email__" data-cfemail="4d1d2c38216309630c292c203e0d243f3e632a223b">[email protected]</span></a>.

SUPPLEMENTARY INFORMATION:
    Title: S Corporation Guidance under Section 958 (Rules for 
Determining Stock Ownership) and Guidance Regarding the Treatment of 
Qualified Improvement Property under the Alternative Depreciation 
System for Purposes of the QBAI Rules for FDII and GILTI.
    OMB Number: 1545-2291.
    Regulation Numbers: TD 9986 and Notice 2020-69.
    Abstract: The Treasury Department and the IRS published final 
regulations (TD 9866) in the Federal Register (84 FR 29288) under Sec.  
951A (final regulations). The final regulations adopted ``aggregate 
treatment'' with respect to income inclusion amounts arising from 
section 951A (the global intangible low tax income inclusion or GILTI) 
for partnerships. Under aggregate treatment, for purposes of 
determining the GILTI inclusion amount of any partner of a domestic 
partnership, each partner is treated as proportionately owning the 
stock of a controlled foreign corporation (CFC) owned by the 
partnership within the meaning of Sec.  958(a) in the same manner as if 
the domestic partnership were a foreign partnership. Because only a 
U.S. person that is a U.S. shareholder can have a GILTI inclusion 
amount, a partner that is not a U.S. shareholder of a partnership-owned 
CFC does not have a GILTI inclusion amount determined by reference to 
the partnership-owned CFC. Section 1.951A-1(e)(1) applies to taxable 
years of foreign corporations beginning after December 31, 2017, and to 
taxable years of U.S. shareholders in which or with which such taxable 
years of foreign corporations' end. Current Actions: There are no 
changes being made to the regulations at this time.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Individuals, or Households.
    Estimated Number of Respondents: 3,688.
    Estimated Time per Respondent: .5 minutes.
    Estimated Total Annual Burden Hours: 1,844 hours.
    The following paragraph applies to all of 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 as long as 
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 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: February 23, 2021.
Chakinna B. Clemons,
Supervisor Tax Analyst.
[FR Doc. 2021-04109 Filed 2-26-21; 8:45 am]
BILLING CODE 4830-01-P


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