The regulations require record maintenance, annual information filing, and the authorization of the U.S. corporation to act as an agent for IRS summons purposes. These requirements allow IRS International examiners to better audit the returns of U.S. corporations engaged in crossborder transactions with a related party.
Expedited clearance is being requested due to the publicâs urgent need for the guidance contained in these regulations. Many of the transactions addressed by these regulations are motivated by tax avoidance, and the expedited release of these regulations is necessary to prevent such avoidance. Taxpayers have an urgent need for this guidance, which is included in these regulations.
US Code:
26 USC 6038A
Name of Law: Information with respect to certain foreign-owned corporations.
The change in likely respondents (foreign owned domestic entities that are disregarded as separate from their owners) with the proposed regulations (REG-127199-15), results in an estimated increase of 1,000 recordkeepers. The amount of time that it takes each recordkeeper to comply with the regulations remains the same at 10 hours per recordkeeper. The increase in the number of recordkeepers increases the total estimated annual burden hours for this information collection by 10,000 for a total of 640,000 burden hours.
$0
No
No
No
No
No
Uncollected
Ronald Gootzeit 202 622-3860
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
SuppStmnt. 1545-1191 2016May.doc
REG-127199-15 - Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A