[Federal Register Volume 79, Number 166 (Wednesday, August 27, 2014)]
[Notices]
[Page 51228]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-20344]
-----------------------------------------------------------------------
DEPARTMENT OF THE TREASURY
Internal Revenue Service
[Notice 2005-38]
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
Notice-2005-38, Limitations on Dividends Received Deduction and Other
Guidance.
DATES: Written comments should be received on or before October 27,
2014 to be assured of consideration.
ADDRESSES: Direct all written comments to R. Joseph Durbala, Internal
Revenue Service, Room 6129, 1111 Constitution Avenue NW., Washington,
DC 20224.
FOR FURTHER INFORMATION CONTACT: Requests for additional information or
copies of the regulation should be directed to Sara Covington, at
Internal Revenue Service, Room 6129, 1111 Constitution Avenue NW.,
Washington, DC 20224, or through the internet, at
[email protected].
SUPPLEMENTARY INFORMATION:
Title: Limitations on Dividends Received Deduction and Other
Guidance.
OMB Number: 1545-1943.
Regulation Project Number: Notice-2005-38.
Abstract: This document provides guidance under new section 965,
which was enacted by the American Jobs Creation Act of 2004 (Pub. L.
108-357). In general, and subject to limitations and conditions,
section 975(a) provides that a corporation that is a U.S. shareholder
of a controlled foreign corporation (CFC) may elect, for one taxable
year, an 85 percent dividends received deduction (DRD) with respect to
certain cash dividends it receives from its CFCs. This document
addresses limitations imposed on the maximum amount of section 965(a)
DRD under section 965(b)(1) (under which the maximum amount of an
eligible dividend is the greatest of $500 million, or earnings
permanently reinvested outside the United States), section 965(b)(2)
(regarding certain base-period repatriations), section 965(b)(3)
(regarding certain increases in related party indebtedness), and
certain miscellaneous limitations (related to the foreign tax credit).
Current Actions: There is no change to this notice.
Type of Review: Extension of OMB approval.
Affected Public: Business or other for-profit organizations.
Estimated Number of Respondents: 25,000.
Estimated Time per Respondent: 50 hours.
Estimated Total Annual Burden Hours: 1,250,000.
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: August 20, 2014.
R. Joseph Durbala,
IRS Supervisory Tax Analyst.
[FR Doc. 2014-20344 Filed 8-26-14; 8:45 am]
BILLING CODE 4830-01-P