[Federal Register Volume 86, Number 43 (Monday, March 8, 2021)]
[Proposed Rules]
[Pages 13250-13251]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-04291]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-101657-20]
RIN 1545-BP70


Guidance Related to the Foreign Tax Credit; Clarification of 
Foreign-Derived Intangible Income; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Proposed rule; notice of hearing.

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SUMMARY: This document provides a notice of public hearing on proposed 
regulations relating to the foreign tax credit and relating to foreign-
derived intangible income, including guidance on the disallowance of a 
credit or deduction for foreign income taxes with respect to dividends 
eligible for a dividends-received deduction; the allocation and 
apportionment of interest expense, foreign income tax expense, and 
certain deductions of life insurance companies; the definition of a 
foreign income tax and a tax in lieu of an income tax; transition rules 
relating to the impact on loss accounts of net operating loss 
carrybacks allowed by reason of the Coronavirus Aid, Relief, and 
Economic Security Act; the definition of foreign branch category and 
financial services income; the time at which foreign taxes accrue and 
can be claimed as a credit; and clarification on the rules relating to 
foreign-derived intangible income.

DATES: The public hearing is being held on Wednesday, April 7, 2021, at 
10:00 a.m. The IRS must receive speakers' outlines of the topics to be 
discussed at the public hearing by Thursday, March 18, 2021. If no 
outlines are received by March 18, 2021, the public hearing will be 
cancelled.

ADDRESSES: The public hearing is being held by teleconference. 
Individuals who want to testify (by telephone) at the public hearing 
must send an email to <a href="/cdn-cgi/l/email-protection#bbcbced9d7d2d8d3dedac9d2d5dcc8fbd2c9c895dcd4cd"><span class="__cf_email__" data-cfemail="a0d0d5c2ccc9c3c8c5c1d2c9cec7d3e0c9d2d38ec7cfd6">[email protected]</span></a> to receive the telephone 
number and access code for the hearing. The subject line of the email 
must contain the regulation number (REG-101657-20) and the word 
TESTIFY. For example, the subject line may say: Request to TESTIFY at 
Hearing for REG-101657-20. The email must include the name(s) of the 
speaker(s) and title(s). Send outline submissions electronically via 
the Federal eRulemaking Portal at www.regulations.gov (IRS REG-101657-
20). The outlines must be received by March 18, 2021 at 
www.regulations.gov, no outlines are being accepted by email.

FOR FURTHER INFORMATION CONTACT: Concerning these proposed regulations, 
Tianlin (Laura) Shi at (202) 317-6987; concerning the hearing, and the 
access code to attend the hearing by teleconferencing, Regina Johnson 
at (202) 317-5177 (not toll-free numbers) or <a href="/cdn-cgi/l/email-protection#374742555b5e545f5256455e595044775e454419505841"><span class="__cf_email__" data-cfemail="48383d2a24212b202d293a21262f3b08213a3b662f273e">[email protected]</span></a>. If 
emailing please put Attend, Testify, or Agenda Request and (REG-101657-
20) in the email subject line.

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking REG-101657-20 that was published in the 
Federal Register on Thursday, November 12, 2020, 85 FR 72078.

[[Page 13251]]

    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments telephonically at the hearing that 
previously submitted written comments by February 10, 2021, must submit 
an outline on the topics to be addressed and the amount of time to be 
devoted to each topic by March 18, 2021.
    A period of 10 minutes is allotted to each person for presenting 
oral comments. After the deadline for receiving outlines has passed, 
the IRS will prepare an agenda containing the schedule of speakers. 
Copies of the agenda will be made available (two days before the 
hearing) by emailing your request to <a href="/cdn-cgi/l/email-protection#423237202e2b212a2723302b2c2531022b30316c252d34"><span class="__cf_email__" data-cfemail="b9c9ccdbd5d0dad1dcd8cbd0d7decaf9d0cbca97ded6cf">[email protected]</span></a>. Please put 
``REG-101657-20 Agenda Request'' in the subject line of the email.
    Individuals who want to attend (by telephone) the public hearing 
must also send an email to <a href="/cdn-cgi/l/email-protection#86f6f3e4eaefe5eee3e7f4efe8e1f5c6eff4f5a8e1e9f0"><span class="__cf_email__" data-cfemail="0c7c796e60656f64696d7e65626b7f4c657e7f226b637a">[email protected]</span></a> to receive the 
telephone number and access code for the hearing. The subject line of 
the email must contain the regulation number (REG-101657-20) and the 
word ``ATTEND''. For example, the subject line may say: Request to 
ATTEND Hearing for REG-101657-20. The email requesting to attend the 
public hearing must be received by 5:00 p.m. two (2) business days 
before the date that the hearing is scheduled.
    The telephonic hearing will be made accessible to people with 
disabilities. To request special assistance during the telephonic 
hearing please contact the Publications and Regulations Branch of the 
Office of Associate Chief Counsel (Procedure and Administration) by 
sending an email to <a href="/cdn-cgi/l/email-protection#d2a2a7b0bebbb1bab7b3a0bbbcb5a192bba0a1fcb5bda4"><span class="__cf_email__" data-cfemail="c0b0b5a2aca9a3a8a5a1b2a9aea7b380a9b2b3eea7afb6">[email protected]</span></a> (preferred) or by telephone 
at (202) 317-5177 (not a toll-free number) at least three (3) days 
prior to the date that the telephonic hearing is scheduled.
    Any questions regarding speaking at or attending a public hearing 
may also be emailed to <a href="/cdn-cgi/l/email-protection#85f5f0e7e9ece6ede0e4f7ecebe2f6c5ecf7f6abe2eaf3"><span class="__cf_email__" data-cfemail="80f0f5e2ece9e3e8e5e1f2e9eee7f3c0e9f2f3aee7eff6">[email protected]</span></a>.

Crystal Pemberton,
Senior Federal Register Liaison, Publications and Regulations Branch, 
Legal Processing Division, Associate Chief Counsel (Procedure and 
Administration).
[FR Doc. 2021-04291 Filed 3-5-21; 8:45 am]
BILLING CODE 4830-01-P


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