[Federal Register Volume 86, Number 42 (Friday, March 5, 2021)]
[Proposed Rules]
[Pages 12886-12887]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-04542]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-111950-20]
RIN 1545-BP91


Guidance on Passive Foreign Investment Companies and the 
Treatment of Qualified Improvement Property Under the Alternative 
Depreciation System for Purposes of Sections 250(b) and 951A(d); 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to a notice of proposed rulemaking.

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SUMMARY: This document contains a correction to a notice of proposed 
rulemaking (REG-111950-20) that was published in the Federal Register 
on January 15, 2021. The proposed regulations regarding the 
determination of whether a foreign corporation is treated as a passive 
foreign investment company (``PFIC'') for purposes of the Internal 
Revenue Code (``Code'').

DATES: Written or electronic comments and requests for a public hearing 
are still being accepted and must be received by April 14, 2021.

ADDRESSES: Send submissions to Internal Revenue Service, CC: PA: LPD: 
PR (REG-111950-20), Room 5205, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044. Alternatively, persons may submit comments 
electronically via the Federal eRulemaking Portal at http://www.regulations.gov (IRS REG-111950-20).

FOR FURTHER INFORMATION CONTACT: Concerning proposed regulations 
Sec. Sec.  1.250(b)-1(b)(2) and 1.250(b)-2(e)(2), Lorraine Rodriguez, 
(202) 317-6726; concerning proposed regulations Sec.  1.951A-3(e)(2), 
Jorge M. Oben and Larry R. Pounders, (202) 317-6934; concerning 
proposed regulations Sec. Sec.  1.1297-0 through 1.1297-2, 1.1298-0 and 
1.1298-4, Christina G. Daniels at (202) 317-6934; concerning proposed 
regulations Sec. Sec.  1.1297-4 through 1.1297-6 (the PFIC insurance 
exception), Josephine Firehock at (202) 317-4932; concerning 
submissions of comments and requests for a public hearing, Regina L. 
Johnson at (202) 317-5177 (not toll-free numbers) or by sending an 
email to <a href="/cdn-cgi/l/email-protection#ff8f8a9d93969c979a9e8d9691988cbf968d8cd1989089"><span class="__cf_email__" data-cfemail="5e2e2b3c32373d363b3f2c3730392d1e372c2d70393128">[email protected]</span></a> (preferred).

SUPPLEMENTARY INFORMATION:

Background

    The proposed regulations that are the subject of this correction 
are under sections 1297 and 1298 of the Internal Revenue Code.

Need for Correction

    As published, the notice of proposed regulations REG-111950-20 
contains errors that needs to be corrected.

Correction of Publication

    Accordingly, the notice of proposed rulemaking (REG-111950-20) that 
was the subject of FR Doc. 2020-27003, published at 86 FR 4582 (January 
15, 2021), is corrected to read as follows:
    1. On page 4589, the first column, the twelfth line from the bottom 
of the last full paragraph, the language ``corporation)'' is corrected 
to read ``corporation'').
    2. On page 4592, the second column, the tenth line from the top of 
the first partial paragraph, the language ``interests'' is corrected to 
read ``interests,''.


Sec.  1.1297-1  [Corrected]

0
3. On page 4603, the first column, in Sec.  1.1297-1, the second line 
and fourth line from the bottom of paragraph (c)(2)(ii)(A), the 
language ``(I)'' is corrected to read``(1); and ``(II)'' is corrected 
to read ``(2)''.


Sec.  1.1297-4   [Corrected]

0
4. On page 4605, the third column, in Sec.  1.1297-4, the second line 
from the bottom of paragraph (f)(6)(i), the language ``statement'' is 
corrected to read ``statement,''.

[[Page 12887]]

0
5. On page 4605, the third column, in Sec.  1.1297-4, the seventh line 
from the bottom of paragraph (f)(6)(ii), the language ``IFRS'' is 
corrected to read ``IFRS,''.
0
6. On page 4605, the third column, in Sec.  1.1297-4, the third line 
from the bottom of paragraph (f)(6)(iii), the language ``IFRS'' is 
corrected to read ``IFRS,''.


Sec.  1.1297-5   [Corrected]

0
7. On page 4606, the third column, in Sec.  1.1297-5, the third line 
from the bottom of paragraph (c)(2)(I)(E), the language ``timeline'' is 
corrected to read ``timeline,''.
0
8. On page 4607, the third column, in Sec.  1.1297-5, the fifth line 
from the top of paragraph (f)(3), the language ``reserves'' is 
corrected to read ``reserves,''.
0
9. On page 4607, in the third column, in Sec.  1.1297-5, the fourth 
line from the top of the first partial paragraph (f)(4), the language 
``management'' is corrected to read ``management,''.
0
10. On page 4607, the third column, in Sec.  1.1297-5, the second line 
from the bottom of paragraph (f)(5), the language ``annuity'' is 
corrected to read ``annuity,''.
0
11. On page 4607, the third column, in Sec.  1.1297-5, the second line 
from the top of paragraph (f)(7), the language ``marketing'' is 
corrected to read ``marketing,''.

Crystal Pemberton,
Senior Federal Register Liaison, Legal Processing Division, Associate 
Chief Counsel, (Procedure and Administration).
[FR Doc. 2021-04542 Filed 3-4-21; 8:45 am]
BILLING CODE 4830-01-P


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