2780 Federal Register / Vol. 80, No. 12 / Tuesday, January 20, 2015 / Notices 

Title: Treatment of Distributions to 

Foreign Persons Under Sections 

367(e)(1) and 367(e)(2). 

OMB Number: 1545–1487. 

Regulation Project Number: REG– 

209827–96 and REG–111672–99. 

Abstract: Section 367(e)(1) provides 

that, to the extent provided in 

regulations, a domestic corporation 

must recognize gain on a section 355 

distribution of stock or securities to a 

foreign person. Section 367(e)(2) 

provides that section 337(a) and (b)(1) 

does not apply to a section 332 

distribution by a domestic corporation 

to a foreign parent corporation that 

owns 80 percent of the domestic 

liquidating corporation (as described in 

section 337(c)). Section 6038B(a) 

requires a U.S. person who transfers 

property to a foreign corporation in an 

exchange described in sections 332 or 

355, among other sections, to furnish to 

the Secretary of the Treasury certain 

information with respect to the transfer, 

as provided in regulations. 

The final regulations under section 

367(e)(1) require gain recognition only 

for distributions of the stock or 

securities of foreign corporations to 

foreign persons. The final regulations 

under section 367(e)(2) generally require 

gain recognition when a domestic 

corporation liquidates into its foreign 

parent corporation; the regulations 

generally do not require gain 

recognition when a foreign corporation 

liquidates into its foreign parent 

corporation. 

This document (TD 9704) contains 

final and temporary regulations relating 

to the consequences to U.S. and foreign 

persons for failing to satisfy reporting 

obligations associated with certain 

transfers of property to foreign 

corporations in nonrecognition 

exchanges. This document permits 

transferors to remedy ‘‘not willful’’ 

failures to file, and ‘‘not willful’’ failures 

to comply with the terms of, liquidation 

documents required under section 

367(e)(2). In addition, this document 

modifies the reporting obligations under 

section 6038B associated with transfers 

that are subject to section 367(e)(2). 

Further, this document provides similar 

rules for certain transfers that are 

subject to section 367(a). The 

regulations are necessary to update the 

rules that apply when a U.S. or foreign 

person fails to file required documents 

or statements or satisfy reporting 

obligations. The regulations affect U.S. 

and foreign persons that transfer 

property to foreign corporations in 

certain non-recognition exchanges. 

Current Actions: There is no change to 

this existing regulation. 

Type of Review: Extension of a 

currently approved collection. 

Affected Public: Business or other forprofit organizations. 

Estimated Number of Respondents: 

217. 

Estimated Time per Respondent: 11 

hours, 23 minutes. 

Estimated Total Annual Burden 

Hours: 2,471. 

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: January 7, 2015. 

Christie Preston, 

IRS, Reports Clearance Officer. 

[FR Doc. 2015–00686 Filed 1–16–15; 8:45 am] 

BILLING CODE 4830–01–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

Proposed Collection; Comment 

Request for Form 8802 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice and request for 

comments. 

SUMMARY: The Department of the 

Treasury, 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 proposed 

and/or continuing information 

collections, as required by the 

Paperwork Reduction Act of 1995, 

Public Law 104–13(44 U.S.C. 

3506(c)(2)(A)). Currently, the IRS is 

soliciting comments concerning Form 

8802, Application for United States 

Residency Certification. 

DATES: Written comments should be 

received on or before March 23, 2015 to 

be assured of consideration. 

ADDRESSES: Direct all written comments 

to Christie Preston at Internal Revenue 

Service, Room 6129, 1111 Constitution 

Avenue NW., Washington, DC 20224. 

FOR FURTHER INFORMATION CONTACT: 

Requests for additional information or 

copies of the form and instructions 

should be directed to R. Joseph Durbala 

at Internal Revenue Service, Room 6129, 

1111 Constitution Avenue NW., 

Washington, DC 20224, or at (202) 317– 

5746, or through the internet at 

RJoseph.Durbala@irs.gov. 

SUPPLEMENTARY INFORMATION: 

Title: Application for United States 

Residency Certification. 

OMB Number: 1545–1817. 

Form Number: Form 8802. 

Abstract: An entity must use Form 

8802 to apply for United States 

Residency Certification. All requests for 

U.S. residency certification must be 

received on Form 8802, Application for 

United States Residency Certification. 

This application must be sent to the 

Philadelphia Service Center. As proof of 

residency in the United States and of 

entitlement to the benefits of a tax 

treaty, U.S. Government certification 

that you are a U.S. citizen, U.S. 

corporation, U.S. partnership, or 

resident of the United States for 

purposes of taxation. 

Current Actions: There are no changes 

being made to the form at this time. 

Type of Review: Extension of a 

currently approved collection. 

Affected Public: Individuals or 

households, business or other for-profit 

organization, and not-for-profit 

institution. 

Estimated Number of Respondents: 

100,000. 

Estimated Time per Respondent: 3 

hours, 38 minutes. 

Estimated Total Annual Burden 

Hours: 363,000. 

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 


rljohnson on DSK3VPTVN1PROD with NOTICES
Federal Register / Vol. 80, No. 12 / Tuesday, January 20, 2015 / Notices 2781 

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: January 8, 2015. 

Christie Preston, 

IRS Reports Clearance Officer. 

[FR Doc. 2015–00687 Filed 1–16–15; 8:45 am] 

BILLING CODE 4830–01–P 

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. 

SUMMARY: The Department of the 

Treasury, 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 proposed 

and/or continuing information 

collections, as required by the 

Paperwork Reduction Act of 1995, 

Public Law 104–13(44 U.S.C. 

3506(c)(2)(A)). Currently, the IRS is 

soliciting comments concerning existing 

Final Regulation, TD 9467— 

Measurement of Assets and Liabilities 

for Pension Funding Purposes, and 

Notice 2014–53—Pension Funding 

Stabilization under the Highway and 

Transportation Funding Act of 2014 

(HAFTA). 

DATES: Written comments should be 

received on or before March 23, 2015 to 

be assured of consideration. 

ADDRESSES: Direct all written comments 

to Christie Preston, Internal Revenue 

Service, Room 6129, 1111 Constitution 

Avenue NW., Washington, DC 20224. 

FOR FURTHER INFORMATION CONTACT: 

Requests for additional information or 

copies of the regulations should be 

directed to Elaine Christophe at Internal 

Revenue Service, Room 6129, 1111 

Constitution Avenue NW., Washington, 

DC 20224, or through the internet at 

Elaine.H.Christophe@irs.gov. 

SUPPLEMENTARY INFORMATION: 

Title: Measurement of Assets and 

Liabilities for Pension Funding 

Purposes. 

OMB Number: 1545–2095. 

Regulation Project Number: REG– 

139236–07 (TD 9467). 

Abstract: In order to implement the 

statutory provisions under sections 430 

and 436, this final regulation contains 

collections of information in 

§§ 1.430(f)–1(f), 1.430(h)(2)–1(e), 1.436– 

1(f), and 1.436–1(h). The information 

required under § 1.430(f)–1(f) is 

required in order for plan sponsors to 

make elections regarding a plan’s credit 

balances upon occasion. The 

information under § 1.430(g)–1(d)(3) is 

required in order for a plan sponsor to 

include as a plan asset a contribution 

made to avoid a restriction under 

section 436. The information required 

under § 1.430(h)(2)–1(e) is required in 

order for a plan sponsor to make an 

election to use an alternative interest 

rate for purposes of determining a plan’s 

funding obligations under § 1.430(h)(2)– 

1. The information required under 

§§ 1.436–1(f) and 1.436–1(h) is required 

in order for a qualified defined benefit 

plan’s enrolled actuary to provide a 

timely certification of the plan’s 

adjusted funding target attainment 

percentage (AFTAP) for each plan year 

to avoid certain benefit restrictions. 

The Highway and Transportation 

Funding Act of 2014 (HATFA), Public 

Law 113–159, was enacted on August 8, 

2014, and was effective retroactively for 

single employer defined benefit pension 

plans, optional for plan years beginning 

in 2013 and mandatory for plan years 

beginning in 2014. Notice 2014–53 

provides guidance on these changes to 

the funding stabilization rules for 

single-employer pension plans. 

Current Actions: There is no change to 

TD 9465 or Notice 2014–53. 

Type of Review: Revision of a 

currently approved collection. 

Affected Public: Individuals, business 

or other for-profit organizations, not-forprofit institutions and Federal, State, 

local or tribal governments. 

TD 9467 

Estimated Number of Respondents: 

80,000. 

Estimated Time per Respondent: 1.5 

hrs. 

Estimated Total Annual Burden 

Hours: 120,000. 

Notice 2014–53 

Estimated Number of Respondents: 

76,600. 

Estimated Time per Respondent: 1 hr. 

Estimated Total Annual Burden 

Hours: 38,000. 

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: January 12, 2015. 

Christie Preston, 

OMB Reports Clearance Officer. 

[FR Doc. 2015–00689 Filed 1–16–15; 8:45 am] 

BILLING CODE 4830–01–P 


rljohnson on DSK3VPTVN1PROD with NOTICES