Federal Register / Vol. 88, No. 218 / Tuesday, November 14, 2023 / Proposed Rules 77921 

(f) Compliance 

Comply with this AD within the 

compliance times specified, unless already 

done. 

(g) Required Actions 

(1) Except as specified in paragraph (h) of 

this AD: Perform all required actions within 

the compliance times specified in, and in 

accordance with, European Union Aviation 

Safety Agency (EASA) AD 2023–0020, dated 

January 23, 2023 (EASA AD 2023–0020). 

(2) The action required by paragraph (g)(1) 

of this AD may be performed by the owner/ 

operator (pilot) holding at least a private pilot 

certificate and must be entered into the 

aircraft records showing compliance with 

this AD in accordance with 14 CFR 43.9(a) 

and 91.417(a)(2)(v). The record must be 

maintained as required by 14 CFR 91.417, 

121.380, or 135.439. 

(h) Exceptions to EASA AD 2023–0020 

(1) Where EASA AD 2023–0020 defines the 

AMP as ‘‘The Aircraft Maintenance 

Programme (AMP) contains the tasks on the 

basis of which the scheduled maintenance is 

conducted to ensure the continuing 

airworthiness of each operated engine,’’ 

replace that text with ‘‘the aircraft 

maintenance program containing the tasks on 

the basis of which the scheduled 

maintenance is conducted to ensure the 

continuing airworthiness of each operated 

airplane.’’ 

(2) Where EASA AD 2023–0020 specifies 

the ALS as ‘‘The Airworthiness Limitations 

Section of the GEAC Engine Maintenance 

Manual (EMM) No. 0982309 Revision 21,’’ 

replace that text with ‘‘The Airworthiness 

Limitations Section of the GEAC Engine 

Maintenance Manual (EMM) No. 0982309 

Revision 22.’’ The ALS in Revision 22 of the 

EMM is unchanged from Revision 21. 

(3) Where EASA AD 2023–0020 refers to its 

effective date, this AD requires using the 

effective date of this AD. 

(4) Where paragraph (3) of EASA AD 2023– 

0020 specifies ‘‘Within 12 months after the 

effective date of this AD, revise the approved 

AMP,’’ replace that text with ‘‘Within 90 

days after the effective date of this AD, revise 

the ALS of the existing approved engine 

maintenance or inspection program, as 

applicable.’’ 

(5) This AD does not require compliance 

with paragraphs (1), (2), (4), and (5) of EASA 

AD 2023–0020. 

(6) This AD does not adopt the Remarks 

paragraph of EASA AD 2023–0020. 

(i) Provisions for Alternative Actions and 

Intervals 

After performing the actions required by 

paragraph (g) of this AD, no alternative 

actions and associated thresholds and 

intervals, including life limits, are allowed 

unless they are approved as specified in the 

provisions of the ‘‘Ref. Publications’’ section 

of EASA AD 2023–0020. 

(j) Terminating Action for Certain Actions 

Required by Affected ADs 

(1) Accomplishing the actions required by 

paragraph (g) of this AD terminates the 

requirements of paragraphs (g)(1) through (3) 

of AD 2021–13–07 for model M601D–11, 

M601E–11, M601E–11A, M601E–11AS, 

M601E–11S, and M601F engines only. 

(2) Accomplishing the actions required by 

paragraph (g) of this AD terminates the 

requirements of paragraphs (g)(1) through (3) 

of AD 2023–01–10 for model M601E–11, 

M601E–11A, M601E–11AS, M601E–11S, and 

M601F engines only. 

(k) Alternative Methods of Compliance 

(AMOCs) 

(1) The Manager, International Validation 

Branch, FAA, has the authority to approve 

AMOCs for this AD, if requested using the 

procedures found in 14 CFR 39.19. In 

accordance with 14 CFR 39.19, send your 

request to your principal inspector or local 

Flight Standards District Office, as 

appropriate. If sending information directly 

to the manager of the International Validation 

Branch, send it to the attention of the person 

identified in paragraph (l) of this AD and 

email to ANE-AD-AMOC@faa.gov. 

(2) Before using any approved AMOC, 

notify your appropriate principal inspector, 

or lacking a principal inspector, the manager 

of the local flight standards district office/ 

certificate holding district office. 

(l) Additional Information 

For more information about this AD, 

contact Barbara Caufield, Aviation Safety 

Engineer, FAA, 1600 Stewart Avenue, Suite 

410, Westbury, NY 11590; phone: (781) 238– 

7146; email: barbara.caufield@faa.gov. 

(m) Material Incorporated by Reference 

(1) The Director of the Federal Register 

approved the incorporation by reference 

(IBR) of the service information listed in this 

paragraph under 5 U.S.C. 552(a) and 1 CFR 

part 51. 

(2) You must use this service information 

as applicable to do the actions required by 

this AD, unless the AD specifies otherwise. 

(i) European Union Aviation Safety Agency 

(EASA) AD 2023–0020, dated January 23, 

2023. 

(ii) [Reserved] 

(3) For EASA AD 2023–0020, contact 

EASA, Konrad-Adenauer-Ufer 3, 50668 

Cologne, Germany; phone: +49 221 8999 000; 

email: ADs@easa.europa.eu; website: 

easa.europa.eu. You may find this EASA AD 

on the EASA website at ad.easa.europa.eu. 

(4) You may view this service information 

at FAA, Airworthiness Products Section, 

Operational Safety Branch, 1200 District 

Avenue, Burlington, MA 01803. For 

information on the availability of this 

material at the FAA, call (817) 222–5110. 

(5) You may view this material at the 

National Archives and Records 

Administration (NARA). For information on 

the availability of this material at NARA, 

visit www.archives.gov/federal-register/cfr/ 

ibr-locations or email fr.inspection@nara.gov. 

Issued on November 2, 2023. 

Victor Wicklund, 

Deputy Director, Compliance & Airworthiness 

Division, Aircraft Certification Service. 

[FR Doc. 2023–24639 Filed 11–13–23; 8:45 am] 

BILLING CODE 4910–13–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Part 1 

[REG–128276–12] 

RIN 1545–BO07 

Recognition and Deferral of Section 

987 Gain or Loss; Comment Period 

Reopening 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking; 

reopening of comment period. 

SUMMARY: The Department of the 

Treasury and the IRS are reopening the 

comment period for REG–128276–12, 

published in the Federal Register on 

December 8, 2016, relating to the 

determination and recognition of 

taxable income or loss and foreign 

currency gain or loss with respect to a 

qualified business unit. 

DATES: The comment period for REG– 

128276–12 (81 FR 88882, December 8, 

2016) (the ‘‘2016 proposed regulations’’) 

is reopened, and additional written or 

electronic comments and requests for a 

public hearing must be received by 

February 12, 2024. 

ADDRESSES: Commenters are strongly 

encouraged to submit additional public 

comments electronically via the Federal 

eRulemaking Portal at https://

www.regulations.gov (indicate IRS and 

REG–128276–12) by following the 

online instructions for submitting 

comments. Requests for a public hearing 

must be submitted as prescribed in the 

‘‘Comments and Requests for a Public 

Hearing’’ section. Once submitted to the 

Federal eRulemaking Portal, comments 

cannot be edited or withdrawn. The 

Department of the Treasury (the 

‘‘Treasury Department’’) and the IRS 

will publish for public availability any 

comments submitted to the IRS’s public 

docket. Send paper submissions to: 

CC:PA:01:PR (REG–128276–12), Room 

5203, Internal Revenue Service, P.O. 

Box 7604, Ben Franklin Station, 

Washington, DC 20044. 

FOR FURTHER INFORMATION CONTACT: Jack 

Zhou at (202) 317–6938; concerning 

submissions of comments, requests for a 

public hearing, or access to a public 

hearing, Vivian Hayes at (202) 317–6901 

(not toll-free numbers) or by email to 

publichearings@irs.gov (preferred). 

SUPPLEMENTARY INFORMATION: On 

December 8, 2016, the Treasury 

Department and the IRS published a 

notice of proposed rulemaking (REG– 

128276–12, 81 FR 88882, December 8, 


khammond on DSKJM1Z7X2PROD with PROPOSALS
77922 Federal Register / Vol. 88, No. 218 / Tuesday, November 14, 2023 / Proposed Rules 

2016) (the ‘‘2016 proposed regulations’’) 

in the Federal Register. The 2016 

proposed regulations cross-reference 

temporary regulations in Treasury 

Decision 9795 (81 FR 88854, December 

8, 2016) (the ‘‘temporary regulations’’), 

which provided rules under section 987 

of the Internal Revenue Code relating to 

the determination and recognition of 

taxable income or loss and foreign 

currency gain or loss with respect to a 

qualified business unit. On May 13, 

2019, the Treasury Department and the 

IRS published Treasury Decision 9857 

(84 FR 20790, May 13, 2019), which 

finalized parts of the 2016 proposed 

regulations and withdrew one section of 

the temporary regulations. The 

temporary regulations that were not 

finalized or withdrawn expired on 

December 6, 2019. A notice of proposed 

rulemaking published in this issue of 

the Federal Register contains new 

proposed regulations under section 987 

and withdraws parts of the 2016 

proposed regulations. The parts of the 

2016 proposed regulations that remain 

outstanding include: (1) rules regarding 

the treatment of section 988 transactions 

of a section 987 QBU (see §§ 1.987–1, 

1.987–3, and 1.988–1 of the 2016 

proposed regulations); (2) rules 

regarding QBUs with the U.S. dollar as 

their functional currency (see §§ 1.987– 

1 and 1.987–6 of the 2016 proposed 

regulations); (3) rules regarding the 

translation of income used to pay 

creditable foreign income taxes (see 

§ 1.987–3 of the 2016 proposed 

regulations); and (4) rules requiring the 

deferral of certain section 988 loss that 

arises with respect to related-party loans 

(see § 1.988–2 of the 2016 proposed 

regulations). 

The Treasury Department and the IRS 

are considering finalizing these parts of 

the 2016 proposed regulations and, 

therefore, are reopening the comment 

period for 90 days. Comments that were 

previously submitted in accordance 

with the 2016 proposed regulations will 

be considered and do not need to be 

resubmitted. 

Comments and Requests for a Public 

Hearing: Before the parts of the 2016 

proposed regulations that remain 

outstanding are adopted as final 

regulations, consideration will be given 

to comments that are submitted timely 

to the IRS as prescribed in this Notice 

in the ‘‘Addresses’’ section. Any 

comments submitted will be made 

available at https://www.regulations.gov 

or upon request. 

A public hearing will be scheduled if 

requested in writing by any person who 

timely submits written comments. 

Requests for a public hearing are also 

encouraged to be made electronically. If 

a public hearing is scheduled, notice of 

the date and time for the public hearing 

will be published in the Federal 

Register. 

Oluwafunmilayo A. Taylor, 

Section Chief, Publications and Regulations 

Section, Associate Chief Counsel, (Procedure 

and Administration). 

[FR Doc. 2023–24650 Filed 11–9–23; 4:15 pm] 

BILLING CODE 4830–01–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Part 53 

[REG–142338–07] 

RIN 1545–BI33 

Taxes on Taxable Distributions From 

Donor Advised Funds Under Section 

4966 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking. 

SUMMARY: This document contains 

proposed regulations regarding excise 

taxes on taxable distributions made by 

a sponsoring organization from a donor 

advised fund (DAF), and on the 

agreement of certain fund managers to 

the making of such distributions. The 

proposed regulations would provide 

guidance regarding DAFs and taxable 

distributions. The proposed regulations 

generally would apply to certain 

organizations, including community 

foundations and other charitable 

organizations, that maintain one or more 

DAFs, and to other persons involved 

with the DAFs, including donors, 

donor-advisors, related persons, and 

certain fund managers. 

DATES: Written or electronic comments 

and requests for a public hearing must 

be received by January 16, 2024. 

ADDRESSES: Commenters are strongly 

encouraged to submit public comments 

electronically. Submit electronic 

submissions via the Federal 

eRulemaking Portal at https://

www.regulations.gov (indicate IRS and 

REG–142338–07) by following the 

online instructions for submitting 

comments. Requests for a public hearing 

must be submitted as prescribed in the 

‘‘Comments and Requests for a Public 

Hearing’’ section. Once submitted to the 

Federal eRulemaking Portal, comments 

cannot be edited or withdrawn. The 

Department of the Treasury (Treasury 

Department) and the IRS will publish 

for public availability any comment 

received to its public docket, whether 

submitted electronically or in hard 

copy. Send paper submissions to: 

CC:PA:01:PR (REG–142338–07), Room 

5203, Internal Revenue Service, P.O. 

Box 7604, Ben Franklin Station, 

Washington, DC 20044. 

FOR FURTHER INFORMATION CONTACT: 

Concerning the proposed regulations, 

Ward L. Thomas at (202) 317–5800 (not 

a toll-free number); concerning 

submission of comments and requests 

for a public hearing, contact Vivian 

Hayes by email at publichearings@

irs.gov (preferred) or by phone at (202) 

317–6901 (not a toll-free number). 

SUPPLEMENTARY INFORMATION: 

Background 

I. Overview 

Some charitable organizations 

(including community foundations) 

establish accounts to which donors may 

contribute and thereafter provide 

nonbinding advice or recommendations 

with regard to distributions from the 

account or the investment of assets in 

the account. Such accounts are 

commonly referred to as ‘‘donor advised 

funds’’ or ‘‘DAFs.’’ Sections 1231–1235 

of the Pension Protection Act of 2006 

(PPA), Public Law 109–280, 120 Stat. 

780, 1094–1102 (August 17, 2006), 

enacted various amendments to the 

Internal Revenue Code (Code) regarding 

DAFs. Among these, section 1232 of the 

PPA amended section 4958 of the Code 

to add special rules relating to excess 

benefit transactions with DAFs; section 

1231(b) of the PPA added section 4967 

to the Code, which imposes an excise 

tax on prohibited benefits resulting from 

distributions from DAFs; and section 

1231(a) of the PPA added section 4966 

of the Code, which imposes excise taxes 

on taxable distributions made by 

sponsoring organizations from a DAF, 

and on the agreement of certain fund 

managers to the making of such 

distributions. This notice of proposed 

rulemaking contains proposed 

amendments to 26 CFR part 53 

(Foundation and Similar Excise Taxes) 

under section 4966 (proposed 

regulations). 

II. Statutory Provisions 

A. Section 4958 

Section 4958 imposes an excise tax on 

any ‘‘excess benefit transaction,’’ which 

is defined generally under section 

4958(c)(1) as any transaction in which 

an economic benefit is provided, the 

value of which exceeds the value of any 

consideration received, by an applicable 

tax-exempt organization (including a 

section 501(c)(3) sponsoring 

organization of a DAF) directly or 

indirectly to or for the use of a 

disqualified person with respect to a 


khammond on DSKJM1Z7X2PROD with PROPOSALS