43998 Federal Register / Vol. 71, No. 149 / Thursday, August 3, 2006 / Proposed Rules 

Alert Service Bulletin PW2000 A72–

706, dated February 17, 2006, that 

describes procedures for a onetime 

focused visual and FPI of suspect 

PW2000 8th stage HPC drum rotor disk 

assemblies that may have been damaged 

during original manufacture. 

FAA’s Determination and Requirements 

of the Proposed AD 

We have evaluated all pertinent 

information and identified an unsafe 

condition that is likely to exist or 

develop on other products of this same 

type design. We are proposing this AD, 

which would require a onetime focused 

visual and FPI of 21 suspect PW2000 

8th stage HPC drum rotor disk 

assemblies. The proposed AD would 

require you to use the service 

information described previously to 

perform these actions. 

Costs of Compliance 

We estimate that this proposed AD 

would affect 15 engines installed on 

airplanes of U.S. registry. We also 

estimate that it would take about 70 

workhours per engine to perform the 

proposed actions, and that the average 

labor rate is $80 per workhour. We do 

not expect that parts will be required. 

Based on these figures, we estimate the 

total cost of the proposed AD to U.S. 

operators to be $84,000 for the 

inspection. 

Authority for This Rulemaking 

Title 49 of the United States Code 

specifies the FAA’s authority to issue 

rules on aviation safety. Subtitle I, 

Section 106, describes the authority of 

the FAA Administrator. Subtitle VII, 

Aviation Programs, describes in more 

detail the scope of the Agency’s 

authority. 

We are issuing this rulemaking under 

the authority described in Subtitle VII, 

Part A, Subpart III, Section 44701, 

‘‘General requirements.’’ Under that 

section, Congress charges the FAA with 

promoting safe flight of civil aircraft in 

air commerce by prescribing regulations 

for practices, methods, and procedures 

the Administrator finds necessary for 

safety in air commerce. This regulation 

is within the scope of that authority 

because it addresses an unsafe condition 

that is likely to exist or develop on 

products identified in this rulemaking 

action. 

Regulatory Findings 

We have determined that this 

proposed AD would not have federalism 

implications under Executive Order 

13132. This proposed AD would not 

have a substantial direct effect on the 

States, on the relationship between the 

national Government and the States, or 

on the distribution of power and 

responsibilities among the various 

levels of government. 

For the reasons discussed above, I 

certify that the proposed regulation: 

1. Is not a ‘‘significant regulatory 

action’’ under Executive Order 12866; 

2. Is not a ‘‘significant rule’’ under the 

DOT Regulatory Policies and Procedures 

(44 FR 11034, February 26, 1979); and 

3. Would not have a significant 

economic impact, positive or negative, 

on a substantial number of small entities 

under the criteria of the Regulatory 

Flexibility Act. 

We prepared a regulatory evaluation 

of the estimated costs to comply with 

this proposed AD. See the ADDRESSES

section for a location to examine the 

regulatory evaluation. 

List of Subjects in 14 CFR Part 39 

Air transportation, Aircraft, Aviation 

safety, Safety. 

The Proposed Amendment 

Under the authority delegated to me 

by the Administrator, the Federal 

Aviation Administration proposes to 

amend 14 CFR part 39 as follows: 

PART 39—AIRWORTHINESS 

DIRECTIVES 

1. The authority citation for part 39 

continues to read as follows: 

Authority: 49 U.S.C. 106(g), 40113, 44701. 

§ 39.13 [Amended] 

2. The FAA amends § 39.13 by adding 

the following new airworthiness 

directive: 

Pratt & Whitney: Docket No. FAA–2006–

24452; Directorate Identifier 2006–NE–

11–AD. 

Comments Due Date 

(a) The Federal Aviation Administration 

(FAA) must receive comments on this 

airworthiness directive (AD) action by 

October 2, 2006. 

Affected ADs 

(b) None. 

Applicability 

(c) This AD applies to Pratt & Whitney 

PW2037, PW2040, PW2037M turbofan 

engines. These engines are installed on, but 

not limited to Boeing 757 airplanes. 

Unsafe Condition 

(d) This AD results from a Pratt & Whitney 

PW2037 8th stage high-pressure compressor 

(HPC) drum rotor disk assembly failure event 

caused by tooling damage that occurred 

during disk assembly manufacture. We are 

issuing this AD to prevent 8th stage HPC 

drum rotor disk assembly failure that could 

result in an uncontained engine failure and 

damage to the airplane. 

Compliance 

(e) You are responsible for having the 

actions required by this AD performed at the 

next shop visit, not to exceed an additional 

6000 engine cycles, after the effective date of 

this AD, when the 8th stage HPC drum rotor 

disk assembly is exposed and removed from 

the HPC module, unless the actions have 

already been done. 

Inspect the 8th Stage Drum Rotor Disk 

(f) Using the Accomplishment Instructions 

of Pratt & Whitney Alert Service Bulletin 

PW2000 A72–706, dated February 17, 2006, 

do a onetime focused visual and fluorescent 

penetrant inspection (FPI) of suspect 8th 

stage HPC drum rotor disk assemblies that 

may have been damaged during manufacture. 

Any 8th stage disk damage that exceeds the 

serviceable limits specified in Pratt & 

Whitney PW2000 Engine Manual, Part 

Number 1A6231, Chapter/Section 72–35–03, 

Inspection/Check–01/–04, can not be 

returned to service. Table 1 of the 

Accomplishment Instructions lists the part 

numbers and serial numbers of the HPC 

drum rotor disk assemblies requiring 

inspection. 

(g) After the effective date of this AD, do 

not install any uninspected 8th stage drum 

rotor disk assemblies listed in Table 1 of the 

Accomplishment Instructions of Pratt & 

Whitney Alert Service Bulletin PW2000 

A72–706, dated February 17, 2006, in any 

engine. 

Alternative Methods of Compliance 

(h) The Manager, Engine Certification 

Office, has the authority to approve 

alternative methods of compliance for this 

AD if requested using the procedures found 

in 14 CFR 39.19. 

Issued in Burlington, Massachusetts, on 

July 27, 2006. 

Francis A. Favara, 

Manager, Engine and Propeller Directorate, 

Aircraft Certification Service. 

[FR Doc. E6–12539 Filed 8–2–06; 8:45 am] 

BILLING CODE 4910–13–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Parts 1 

[REG–125071–06] 

RIN 1545–BF75 

Reporting Rules for Widely Held Fixed 

Investment Trusts 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking 

by cross-reference to temporary 

regulations. 

SUMMARY: In this issue of the Federal 

Register, the IRS and the Treasury 

Department are issuing final and 

temporary regulations amending 


hsrobinson on PROD1PC69 with PROPOSALS
Federal Register / Vol. 71, No. 149 / Thursday, August 3, 2006 / Proposed Rules 43999 

§ 1.671–5 which provides reporting 

rules for widely held fixed investment 

trusts (WHFITs). The final and 

temporary regulations clarify and 

simplify reporting for trustees and 

middlemen of non-mortgage widely 

held fixed investment trusts 

(NMWHFITs). The text of those final 

and temporary regulations serves, in 

part, as the text of these proposed 

regulations. In addition to the 

amendments to § 1.671–5 included in 

the final and temporary regulations, 

these proposed regulations provide for 

the creation of a directory of 

NMWHFITs and trustees of widely held 

mortgage trusts (WHMTs). These 

regulations also clarify the reporting 

rules for market discount under the 

NMWHFIT safe harbor for NMWHFITs 

that hold debt instruments with original 

issue discount (OID). The preamble to 

these regulations also solicits comments 

regarding the safe harbor for WHMTs. 

DATES: Written or electronic comments 

and requests for a public hearing must 

be received by October 2, 2006. 

ADDRESSES: Send submissions to 

CC:PA:LPD:PR (REG–125071–06), 

Internal Revenue Service, PO Box 7604, 

Ben Franklin Station, Washington, DC 

20044, or send electronically, via the 

IRS Internet site at http://www.irs.gov/ 

regs or via the Federal eRulemaking 

Portal at http://www.regulations.gov 

(IRS–REG–125071–06). 

FOR FURTHER INFORMATION CONTACT: 

Concerning the proposed regulations, 

Faith Colson, (202) 622–3060 (not a tollfree number); concerning submission of 

comments and/or requests for a public 

hearing, Richard A Hurst at 

Richard.A.Hurst@irscounsel.treas.gov. 

SUPPLEMENTARY INFORMATION: 

Paperwork Reduction Act 

These proposed regulations amend 

§ 1.671–5. The collection of information 

contained in these proposed regulations 

has been previously reviewed and 

approved by the Office of Management 

and Budget in accordance with the 

Paperwork Reduction Act of 1995 (44 

U.S.C. 3507) under control number 

1545–1540. Response to this collection 

of information is mandatory. The 

collection of information in these 

proposed regulations is in § 1.671–5. 

This information is required to be 

reported to beneficial owners of trust 

interests to enable them to correctly 

report their share of the items of 

income, deduction, and credit of the 

WHFIT in which they have invested. 

This information is also required to be 

reported to the IRS to enable the IRS to 

verify that trustees and middlemen are 

accurately reporting information to 

beneficial owners of trust interests and 

that beneficial owners are properly 

reporting their ownership of a trust 

interest. 

An agency may not conduct or 

sponsor, and a person is not required to 

respond to, a collection of information 

unless it displays a valid control 

number assigned by the Office of 

Management and Budget. 

Books or records relating to a 

collection of information must be 

retained as long as their contents might 

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. 

Background and Explanation of 

Provisions 

On January 24, 2006, the Internal 

Revenue Service (IRS) and the Treasury 

Department published final regulations 

(TD 9241) under § 1.671–5 in the 

Federal Register (71 FR 4002) providing 

reporting rules for WHFITs. Final and 

temporary regulations in this issue of 

the Federal Register amend § 1.671–5. 

These amendments are intended to 

clarify and simplify the reporting 

required by NMWHFITs under § 1.671–

5. The text of the final and temporary 

regulations also serves, in part, as the 

text of these proposed regulations. The 

preamble to final and temporary 

regulations explains the final and 

temporary regulations and those parts of 

these proposed regulations that are 

included in the final and temporary 

regulations. These proposed regulations 

include proposed amendments to 

§ 1.671–5 in addition to those provided 

by the final and temporary regulations. 

The proposed amendments to § 1.671–5 

that are not included in the final and 

temporary regulations are discussed 

below. 

I. Proposed Directory of WHMT Trustees 

and NMWHFITs and Requirement That 

WHMT Trustees Provide a List of 

WHMTs for Which They Act on an 

Internet Web Site 

Prior to the publication of the final 

regulations under § 1.671–5, 

commentators expressed concern that 

middlemen would not be able to 

identify a client’s investment as an 

investment in a WHFIT and suggested 

that the IRS publish a directory or list 

of WHFITs that would include the name 

and CUSIP number of each WHFIT, 

along with the name, address and 

telephone number of the WHFIT’s 

representative. Commentators noted that 

a publicly available directory or list 

would assist middlemen and brokers in 

identifying a client’s investment as an 

investment in a WHFIT and in locating 

the WHFIT’s representative. 

In response to these comments, the 

final regulations require a trustee to 

identify the WHFIT as either a WHMT 

or a NMWHFIT when providing trust 

information. The preamble to the final 

WHFIT regulations provides that the 

IRS and the Treasury Department are 

studying whether a directory or list of 

WHFITs can be compiled by the IRS and 

expressed concern that such a directory 

was not feasible because of the large 

number of WHMTs. In the preamble, the 

IRS and the Treasury Department 

requested additional comments from 

middlemen regarding the type of 

WHFITs that should be included in any 

directory, the type of information 

needed by middlemen (especially 

middlemen holding WHMT interests), 

and the format of a directory that would 

be most helpful. Trustees were also 

asked to comment regarding how the 

IRS could obtain the trust information 

needed for the directory from the 

trustees in the least burdensome 

manner. 

Since the publication of the final 

regulations, the IRS has received 

additional comments regarding the need 

for a directory of WHFITs. 

Commentators indicated that such a 

directory would significantly improve a 

middleman’s ability to comply with 

§ 1.671–5 and suggested that the IRS 

provide a directory of WHMT trustees 

and NMWHFITs, with each WHMT 

trustee maintaining a list of the WHMTs 

for which the trustee acts at an Internet 

Web site available to middlemen. 

In response to these comments, the 

IRS proposes to expand Publication 938, 

‘‘Real Estate Investment Conduits 

(REMICs) Reporting Information (and 

other Collateralized Debt Obligations 

(CDOs)),’’ or create a separate 

publication to list WHMT trustees and 

NMWHFITs. The IRS currently intends 

to list NMWHFITs in this directory by 

trustee (listed in alphabetical order) 

with the NMWHFITs for which the 

trustee acts listed by CUSIP number, 

followed by any NMWHFITs, listed in 

alphabetical order by name which do 

not have CUSIP numbers. NMWHFIT 

trustees will be required to file Form 

8811, ‘‘Information Return for REMICs 

and Issuers of CDO’s,’’ or a similar form 

to provide the IRS with the information 

it needs to list NMWHFITs in the 

directory. 

The directory will also alphabetically 

list WHMT trustees and provide the 

address of the Internet Web site that 

lists the WHMTs for which the trustee 

acts. WHMT trustees will be required to 

file Form 8811, or similar form, to 

identify themselves to the IRS as a 


hsrobinson on PROD1PC69 with PROPOSALS
44000 Federal Register / Vol. 71, No. 149 / Thursday, August 3, 2006 / Proposed Rules 

WHMT trustee and provide an Internet 

Web site that lists the WHMTs for 

which the trustee acts. The IRS and 

Treasury Department continue to 

request comments on the need for the 

directory and the format to be used for 

the directory, as well as comments 

regarding how to obtain information 

from trustees in the least burdensome 

manner. 

II. Clarification of Market Discount 

Information Required To Be Reported 

Under the NMWHFIT Safe Harbor 

Commentators also noted the need for 

amendments to the information required 

to be reported under the NMWHFIT safe 

harbor with respect to market discount. 

If a NMWHFIT does not qualify for the 

reduced reporting in § 1.671–

5(c)(2)(iv)(B), § 1.671–5(f)(1)(viii) 

requires the trustee to provide 

information regarding the portion of the 

trust that the assets sold represented. 

Assuming that a trust interest holder 

purchased its interest at a discount, it 

was contemplated that the trust interest 

holder would allocate the same portion 

of its discount to the sale as the assets 

represented to the NMWHFIT. The trust 

interest holder would then determine 

how much of the discount allocated to 

the sold assets had accrued since the 

trust interest holder purchased its 

interest using either a ratable or 

constant interest method, as 

appropriate. 

After reviewing the comments 

received after the publication of TD 

9241, the IRS and the Treasury 

Department noted that the information 

required to be reported under the safe 

harbor is incomplete with respect to a 

NMWHFIT holding debt instruments 

with original issue discount (OID). 

Under both the general provisions 

(§ 1.671–5(c)(2)(ii)(A) and (vii)) and the 

safe harbor (§ 1.671–5(f)(1)(vii) and 

(viii)), OID information is required to be 

calculated and provided separately from 

market discount. Accordingly, to enable 

trust interest holders to determine the 

amount of market discount the interest 

holder is to allocate to a particular sale 

or disposition of debt instruments by 

the NMWHFIT, § 1.671–5(f)(1)(viii)(A) is 

proposed to be amended with respect to 

NMWHFITs that hold debt instruments 

with OID, to include a requirement that 

trustees provide the aggregate adjusted 

issue price of the debt instruments held 

by the NMWHFIT per trust interest as of 

the start-up date as well as of January 1 

of each subsequent year of the 

NMWHFIT. It is contemplated that trust 

interest holders will use the January 1 

adjusted issue price for the year in 

which the trust interest holder 

purchased its interest to determine 

whether a trust interest was acquired 

with market discount. So as not to 

require trustees to calculate information 

for calendar years prior to the effective 

date of the final regulations, the 

proposed regulations only apply this 

requirement to NMWHFITs with a startup date (as defined in § 1.671–5(b)(19)) 

after January 24, 2006. 

III. Request for Comments on the 

Expansion of the WHMT Safe Harbor 

The final regulations include safe 

harbor reporting rules for WHMTs. 

Section 1.671–5(g)(1)(ii)(B) provides 

that, to be eligible to report under the 

WHMT safe harbor, all interests in the 

WHMT must represent the right to 

receive an equal pro-rata share of both 

the income and the principal payments 

received by the WHMT on the 

mortgages it holds and that, for 

example, a WHMT that holds or issues 

trust interests that qualify as stripped 

interests under section 1286 may not 

report under the safe harbor. Further, a 

WHMT that holds an interest in another 

WHFIT is not eligible to report under 

the WHMT safe harbor. See § 1.671–

5(b)(11) (limiting the definition of a 

mortgage to exclude an interest in 

another WHFIT) and § 1.671–

5(g)(1)(ii)(E)(1) (providing that only 

WHMTs that directly hold mortgages 

may use the safe harbor). Since the 

publication of the final regulations, a 

commentator has requested that safe 

harbor reporting rules be developed for 

WHMTs that hold or issue stripped 

interests and for WHMTs that hold 

interests in other WHMTs. The IRS and 

the Treasury Department will consider 

this request in connection with further 

action on this proposed regulation and 

request additional comments regarding 

the need for additional WHMT safe 

harbor reporting rules, the nature of the 

arrangements for which the additional 

safe harbors are needed, the safe harbor 

reporting suggested and how such 

reporting is consistent with substantive 

law. 

Effective Date 

The IRS and the Treasury Department 

expect to take prompt action to finalize 

the proposed regulations so that certain 

of the provisions that are only included 

in the proposed regulations can be made 

effective as of January 1, 2007 (see 

§ 1.671–5(m)) as though the provisions 

were included in TD 9241. The IRS and 

Treasury Department invite 

recommendations regarding the 

effective date of proposed paragraphs 

(c)(3) (requiring trustees to file an 

information return with the IRS and 

requiring WHMT trustees to provide an 

Internet Web site listing the WHMTs for 

which they act) and (c)(5) (providing for 

middlemen to refer to a directory 

created by the IRS), that may require 

some lead time for their 

implementation. 

Special Analysis 

It has been determined that these 

proposed regulations are not a 

significant regulatory action as defined 

in Executive Order 12866. Therefore, a 

regulatory assessment is not required. It 

is hereby certified that these regulations 

will not have a significant economic 

impact on a substantial number of small 

entities. This certification is based on 

the fact that the regulations will not to 

have a significant economic impact on 

small entities because the reporting 

burdens in these regulations will fall 

primarily on large brokerage firms, large 

banks, and other large entities acting as 

trustees or middlemen, most of which 

are not small entities within the 

meaning of the Regulatory Flexibility 

Act (5 U.S.C. chapter 6). Thus, a 

substantial number of small entities are 

not expected to be affected. Therefore, a 

Regulatory Flexibility Analysis under 

the Regulatory Flexibility Act (5 U.S.C. 

chapter 6) is not required. Pursuant to 

section 7805(f) of the Code, these 

regulations will be submitted to the 

Chief Counsel for Advocacy of the Small 

Business Administration for comment 

on their impact on small business. 

Comments and Public Hearing 

Before these proposed regulations are 

adopted as final regulations, 

consideration will be given to any 

written (a signed original and eight (8) 

copies) or electronic comments that are 

submitted timely to the IRS. The IRS 

and the Treasury Department request 

comments on the clarity of the proposed 

rules and how they can be made easier 

to understand. All comments will be 

available for public inspection and 

copying. A public hearing will be 

scheduled if requested in writing by any 

person that timely submits written 

comments. If a public hearing is 

scheduled, notice of the date, time, and 

place for the public hearing will be 

published in the Federal Register. 

Drafting Information 

The principal author of these 

regulations is Faith Colson, Office of 

Associate Chief Counsel (Passthroughs 

& Special Industries). However, other 

personnel from the IRS and the Treasury 

Department participated in their 

development. 

List of Subjects in 26 CFR Part 1 

Income taxes, Reporting and 

recordkeeping requirements. 


hsrobinson on PROD1PC69 with PROPOSALS
Federal Register / Vol. 71, No. 149 / Thursday, August 3, 2006 / Proposed Rules 44001 

Proposed Amendments to the 

Regulations 

Accordingly, 26 CFR part 1 is 

amended as follows: 

PART 1—INCOME TAXES 

Paragraph 1. The authority citation 

for part 1 continues to read, in part, as 

follows: 

Authority: 26 U.S.C. 7805 * * * 

Par. 2. Section 1.671–5 is amended 

by: 

1. Revising paragraphs (b)(5), (b)(8), 

and (b)(21). 

2. Revising paragraph (c)(2)(iv), (v)(C), 

(vi), and (vii). 

3. Revising paragraph (c)(3). 

4. Adding paragraph (c)(5)(iv). 

5. Revising paragraphs (f)(1)(i)(A) and 

(viii)(A). 

The revisions and addition read as 

follows: 

§ 1.671–5 Reporting for widely held fixed 

investment trusts. 

* * * * * 

(b) * * * 

(5) [The text of proposed § 1.671–

5(b)(5) is the same as the text of § 1.671–

5T(b)(5) published elsewhere in this 

issue of the Federal Register]. 

* * * * * 

(8) [The text of proposed § 1.671–

5(b)(8) is the same as the text of § 1.671–

5T(b)(8) published elsewhere in this 

issue of the Federal Register]. 

* * * * * 

(21) [The text of proposed § 1.671–

5(b)(21) is the same as the text of 

§ 1.671–5T(b)(21) published elsewhere 

in this issue of the Federal Register]. 

* * * * * 

(c) * * * 

(2) * * * 

(iv) [The text of proposed § 1.671–

5(c)(2)(iv) is the same as the text of 

§ 1.671–5T(c)(2)(iv) published 

elsewhere in this issue of the Federal 

Register]. 

(v) * * * 

(C) [The text of proposed § 1.671–

5(c)(2)(v)(C) is the same as the text of 

§ 1.671–5T(c)(2)(v)(C) published 

elsewhere in this issue of the Federal 

Register]. 

(vi) [The text of proposed § 1.671–

5(c)(2)(vi) is the same as the text of 

§ 1.671–5T(c)(2)(vi) published 

elsewhere in this issue of the Federal 

Register]. 

(vii) [The text of proposed § 1.671–

5(c)(2)(vii) is the same as the text of 

§ 1.671–5T(c)(2)(vii) published 

elsewhere in this issue of the Federal 

Register]. 

* * * * * 

(3) Requirement that trustees file an 

information return and that WHMT 

trustees list WHMTs on an Internet Web 

site—(i) Information return identifying a 

NMWHFIT to the IRS. For each 

NMWHFIT for which the trustee acts, 

the trustee of a NMWHFIT must file the 

form specified as the information return 

to be used for identifying a NMWHFIT 

to the IRS. The form must be filed by the 

due date provided by that form and 

must contain the information required 

to be provided by the form. If, following 

the publication of final regulations in 

the Federal Register, the IRS issues 

additional guidance that prescribes 

another method to be used to identify 

and provide information with respect to 

a NMWHFIT to the IRS, this method 

must be used. 

(ii) Information return for trustees of 

WHMTs and the requirement that the 

trustee maintain an Internet Web site 

listing the CUSIP numbers and names of 

the WHMTs for which the trustee acts. 

The trustee of a NMWHFIT must file the 

form specified as the information return 

to be used for identifying the trustee to 

the IRS. The form must be filed by the 

due date provided by that form and 

contain the information required to be 

provided by the form. In addition, the 

trustee must maintain a list of the 

WHMTs for which the trustee acts on 

the trustee’s Internet Web site (or 

another site designated by the trustee for 

this purpose). If, following the 

publication of final regulations in the 

Federal Register, the IRS issues 

additional guidance that prescribes 

another method to be used to identify a 

trustee as a WHMT trustee and provide 

information with respect to the WHMTs 

for which the trustee acts, this method 

must be used. 

* * * * * 

(5) * * * 

(iv) Directory of WHMT trustees and 

NMWHFITs. The IRS provides a 

directory of WHMT trustees and 

NMWHFITs, and WHMT trustees 

provide an Internet Web site at which 

the trustees list the WHMTs for which 

they act, to assist requesting persons in 

locating a representative of a WHFIT 

that will provide the information 

specified in paragraph (c) of this 

section. A requesting person may report 

consistent with this section for any 

arrangement identified in the directory 

as a NMWHFIT or on a WHMT trustee’s 

Internet Web site as a WHMT provided 

that the requesting person does not have 

actual knowledge that the arrangement 

is not a WHFIT. 

(f) * * * 

(1) * * * 

(i) * * * 

(A) [The text of proposed § 1.671–

5(f)(1)(i)(A) is the same as the text of 

§ 1.671–5T(f)(1)(i)(A) published 

elsewhere in this issue of the Federal 

Register]. 

* * * * * 

(viii) Reporting market discount 

information under the safe harbor—(A) 

In general—(1) Trustee is required to 

provide market discount information. If 

the trustee is required to provide 

information regarding market discount 

under paragraph (c)(2)(vii) of this 

section, the trustee must provide—

(i) The information required to be 

provided under paragraph 

(f)(1)(iv)(A)(1)(iii) of this section; and 

(ii) If the NMWHFIT holds debt 

instruments with OID and the 

NMWHFIT has a start-up date on or 

after January 24, 2006, the aggregate 

adjusted issue price of the debt 

instruments per trust interest calculated 

as of the start-up date and as of January 

1 for each subsequent year of the 

NMWHFIT. 

(2) Trustee is not required to provide 

market discount information. If the 

trustee is not required to provide market 

discount information under paragraph 

(c)(2)(vii) of this section (because the 

NMWHFIT meets the de minimis test of 

paragraph (c)(2)(iv)(D)(1) of this section, 

the qualified NMWHFIT exception of 

paragraph (c)(2)(iv)(E) of this section, or 

the NMWHFIT final year exception of 

paragraph (c)(2)(iv)(F) of this section), 

the trustee is not required under this 

paragraph (f) to provide any information 

regarding market discount. 

* * * * * 

Mark E. Matthews, 

Deputy Commissioner for Services and 

Enforcement. 

[FR Doc. 06–6650 Filed 7–28–06; 4:15 pm] 

BILLING CODE 4830–01–P 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

50 CFR Part 216 

[Docket No. 060629183–6183–01; I.D. 

022106A] 

RIN 0648–AT39 

Taking and Importing Marine 

Mammals; Taking Marine Mammals 

Incidental to Conducting Precision 

Strike Weapons Testing and Training 

by Eglin Air Force Base in the Gulf of 

Mexico 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 


hsrobinson on PROD1PC69 with PROPOSALS