{"abstract":"This document contains proposed regulations that would treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Internal Revenue Code. These changes are intended to provide the IRS with improved access to information that it needs to satisfy its obligations under U.S. tax treaties, tax information exchange agreements and similar international agreements, as well as to strengthen the enforcement of U.S. tax laws.","action":"Notice of proposed rulemaking.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2016/05/10/2016-10852.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26},{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"81 FR 28784","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by August 8, 2016.","disposition_notes":null,"docket_ids":["REG-127199-15"],"dockets":[],"document_number":"2016-10852","effective_on":null,"end_page":28788,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2016/05/10/2016-10852.xml","html_url":"https://www.federalregister.gov/documents/2016/05/10/2016-10852/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2016-10852?publication_date=2016-05-10","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2016-05-10/2016-10852/mods.xml","not_received_for_publication":null,"page_length":5,"page_views":{"count":2578,"last_updated":"2026-08-25 02:15:03 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2016-05-10/pdf/2016-10852.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2016-10852.pdf?1462538804","publication_date":"2016-05-10","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2016/05/10/2016-10852.txt","regulation_id_number_info":{"1545-BM94":{"issue":"201610","html_url":"https://www.federalregister.gov/regulations/1545-BM94/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038(A)","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201610&RIN=1545-BM94&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BM94"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BM94/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038(A)"},"comments_count":0,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2016-0019","supporting_documents_count":0,"docket_id":"IRS-2016-0019","document_id":"IRS-2016-0019-0001","regulation_id_number":"1545-BM94","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A (REG-127199-15)","checked_regulationsdotgov_at":"2022-02-16T04:30:04Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":28784,"subtype":null,"title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A","toc_doc":"Treatment of Certain Domestic Entities Disregarded as Separate from Their Owners as Corporations as Corporations for Purposes of Section 6038A","toc_subject":null,"topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":81}