Taxable Income or Loss and Currency Gain or Loss With

Official source: Federal Register (GovInfo) (https://www.govinfo.gov/content/pkg/FR-2025-01-17/pdf/2025-01248.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

5606 Federal Register / Vol. 90, No. 11 / Friday, January 17, 2025 / Rules and Regulations

List of Subjects in 25 CFR Part 575

Administrative practice and procedure, Gaming, Indians-lands, Penalties.

For the reasons set forth in the preamble, the Commission amends 25 CFR part 575 as follows:

PART 575—CIVIL FINES

1. The authority citation for part 575 continues to read as follows:

Authority: 25 U.S.C. 2705(a), 2706, 2713, 2715; and Sec. 701, Pub. L. 114–74, 129 Stat. 599.

§ 575.4 [Amended]

1. Amend § 575.4, in the introductory text, by removing ‘‘$63,992’’ and adding in its place ‘‘$65,655’’.

Dated: January 13, 2025. Sharon M. Avery, Chair (Acting). Jean C. Hovland, Vice Chair.

[FR Doc. 2025–01060 Filed 1–16–25; 8:45 am]

BILLING CODE 7565–01–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 10016]

RIN 1545–BO07

Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final rule; correction and correcting amendments.

SUMMARY: This document includes corrections to a final regulation (Treasury Decision 10016) published in the Federal Register on Wednesday, December 11, 2024. Treasury Decision 10016 contained final regulations relating to the determination of taxable income or loss and foreign currency gain or loss with the respect to a qualified business unit.

DATES: These corrections are effective on January 17, 2025. For dates of applicability, see § 1.987–15.

FOR FURTHER INFORMATION CONTACT: Concerning the final regulations generally, Adam G. Province at (865) 329–4546; concerning the character and source of section 987 gain or loss, Larry Pounders at (202) 317–5465; concerning consolidated groups, Jeremy Aron-Dine

Regulatory Flexibility Act

The Commission certifies that this rule will not have a significant economic effect on a substantial number of small entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq. ) because the rule makes annual adjustments for inflation.

Small Business Regulatory Enforcement Fairness Act

This final rule is not a major rule under 5 U.S.C. 804(2), the Small Business Regulatory Enforcement Fairness Act. It will not result in the expenditure by state, local, or tribal governments, in the aggregate, or by the private sector of $100 million or more in any one year. The rule will not result in a major increase in costs or prices for consumers, individual industries, federal, state, or local government agencies, or geographic regions. Nor will this rule have significant adverse effects on competition, employment, investment, productivity, innovation, or the ability of the U.S.-based enterprises to compete with foreign-based enterprises.

Unfunded Mandates Reform Act

This final rule does not impose an unfunded mandate of more than $100 million per year on state, local, or tribal governments or the private sector. The rule also does not have a significant or unique effect on state, local, or tribal governments or the private sector. Therefore, a statement containing the information required by the Unfunded Mandates Reform Act (2 U.S.C. 1531 et seq. ) is not required.

Takings

Under the criteria in Executive Order 12630, this final rule does not affect individual property rights protected by the Fifth Amendment nor does it involve a compensable ‘‘taking.’’ Thus, a takings implication assessment is not required.

Federalism

Under the criteria in Executive Order 13132, this final rule has no substantial direct effect on the states, on the relationship between the national government and the states, or on the distribution of power and responsibilities among the various levels of government.

Civil Justice Reform

This final rule complies with the requirements of Executive Order 12988. Specifically, this rule has been reviewed to eliminate errors and ambiguity and written to minimize litigation. It is

written in clear language and contains clear legal standards.

Consultation With Indian Tribes

In accordance with the President’s memorandum of April 29, 1994, Government-to-Government Relations with Native American Tribal Governments, Executive Order 13175 (59 FR 22951, November 6, 2000), the Commission has determined that consultations with Indian gaming tribes is not practicable, as Congress has mandated that annual civil penalty adjustments in the Act be implemented no later than January 15th of each year.

Paperwork Reduction Act

This final rule does not affect any information collections under the Paperwork Reduction Act.

National Environmental Policy Act

This final rule does not constitute a major federal action significantly affecting the quality of the human environment.

Information Quality Act

In developing this final rule, the Commission did not conduct or use a study, experiment, or survey requiring peer review under the Information Quality Act (Pub. L. 106–554).

Effects on the Energy Supply

This final rule is not a significant energy action under the definition in Executive Order 13211. A Statement of Energy Effects is not required.

Clarity of this Regulation

The Commission is required by Executive Orders 12866 and 12988 and by the Presidential Memorandum of June 1, 1998, to write all rules in plain language. This means that each rule that the Commission publishes must:

(a) be logically organized; (b) use the active voice to address readers directly;

(d) be divided into short sections and sentences; and

(e) use lists and tables wherever possible.

Required Determinations Under the Administrative Procedure Act

In accordance with the Act, agencies are to annually adjust civil monetary penalties without providing an opportunity for notice and comment, and without a delay in its effective date. Therefore, the Commission is not required to complete a notice and comment process prior to promulgation.

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Federal Register / Vol. 90, No. 11 / Friday, January 17, 2025 / Rules and Regulations 5607

at (202) 317–6847 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

The final regulations (TD 10016) that are the subject of this correction are under sections 861, 985 through 989, and 1502 of the Internal Revenue Code.

Corrections to Publication

Accordingly, FR Doc. 2024–28372 (TD 10016) appearing on page 100138 in the Federal Register on Wednesday, December 11, 2024, is corrected as follows:

On page 100155, in the third column, under the caption ‘‘A. Loss Suspension Rule 1. In General’’, the second line of the third full paragraph is corrected to read ‘‘proposed § 1.987– 11(c)’’.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Correction to the Regulations

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * -

Par. 2. Section 1.987–1 is amended by revising the first sentence of paragraph (b)(3)(ii)(A) to read as follows:

§ 1.987–1 Scope, definitions, and special rules.

- - - (b) * - (3) * - (ii) * - (A) * - - Solely for purposes of section 987, an owner may elect to treat all section 987 QBUs with the same functional currency as a single section 987 QBU except to the extent provided in paragraph (b)(3)(ii)(B) of this section.

Par. 3. Section 1.987–2 is amended by revising the second sentence of paragraph (c)(10)(xviii)(B)( 2 ) to read as follows:

§ 1.987–2 Attribution of items to eligible QBUs; definition of a transfer and related rules.

- - - (c) * - (10) * - (xviii) * - (B) * -

( 2 ) * - - Under § 1.987–5(c)(4) and § 1.987–8(e), a termination of a section 987 QBU is treated as a remittance of all the gross assets of the section 987 QBU to the owner on the date of the termination. * -

§ 1.1502–13 [Amended]

Par. 4. Section 1.1502–13 is amended by redesignating the second occurrence of paragraph (j)(10)(vi) as (j)(10)(vii).

Regina L. Johnson, Federal Register Liaison, Publications and Regulations Section, Associate Chief Counsel (Procedure and Administration).

[FR Doc. 2025–01248 Filed 1–16–25; 8:45 am]

BILLING CODE 4830–01–P

DEPARTMENT OF JUSTICE

Office of the Attorney General

28 CFR Part 0

[Docket No. OAG 172; AG Order No. 6146– 2025]

Office of Legal Policy

AGENCY: Department of Justice.

ACTION: Final rule.

SUMMARY: This rule amends the Code of Federal Regulations to update the organizational description of the Office of Legal Policy to reflect current practice.

DATES: This rule is effective January 17, 2025.

FOR FURTHER INFORMATION CONTACT: Robert Hinchman, Senior Counsel, Office of Legal Policy, U.S. Department of Justice, RFK Main Justice Building, 950 Pennsylvania Avenue NW, Room 4252, Washington, DC 20530. Telephone: (202) 514–8059.

SUPPLEMENTARY INFORMATION:

I. Background

In the Department of Justice’s organizational regulations, 28 CFR 0.23 describes the ‘‘General Functions’’ of the Office of Legal Policy (‘‘OLP’’), but some of those provisions are out of date. For that reason, this final rule revises § 0.23 to better reflect OLP’s current structure and functions. The final rule also removes two other regulatory provisions—28 CFR 0.23b and 0.15(f)— because they reference a former OLP entity that no longer exists.

II. Administrative Procedure Act

This rule is a rule of agency organization and procedure, and relates to the internal management of the

Department of Justice. It is therefore exempt from the requirements of notice and comment and a delayed effective date. 5 U.S.C. 553(b), (d).

III. Regulatory Requirements

A. Regulatory Flexibility Act

A Regulatory Flexibility Analysis is not required to be prepared for this final rule since the Department was not required to publish a general notice of proposed rulemaking for this matter. See 5 U.S.C. 604(a).

B. Executive Orders 12866, 13563, and 14094: Regulatory Planning and Review This final rule has been drafted and reviewed in accordance with Executive Order 12866 (Regulatory Planning and Review), Executive Order 13563 (Improving Regulation and Regulatory Review), and Executive Order 14094 (Modernizing Regulatory Review). This action is limited to agency organization, management, and personnel matters and therefore is not a ‘‘regulation’’ or ‘‘rule’’ under Executive Order 12866, section 3(d)(3). Accordingly, this action has not been reviewed by the Office of Management and Budget.

C. Executive Order 13132: Federalism

This rule will not have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government. Therefore, in accordance with section 6 of Executive Order 13132, the Department has determined that this rule does not have federalism implications warranting the preparation of a federalism summary impact statement.

D. Executive Order 12988: Civil Justice Reform

This rule meets the applicable standards set forth in sections 3(a) and 3(b)(2) of Executive Order 12988.

E. Unfunded Mandates Reform Act of 1995 This rule will not result in the expenditure by State, local, and Tribal governments, in the aggregate, or by the private sector, of $100,000,000 or more in any one year (adjusted for inflation), and it does not establish requirements that might significantly or uniquely affect small governments. Therefore, no actions were deemed necessary under the provisions of the Unfunded Mandates Reform Act of 1995.

F. Congressional Review Act

This action pertains to agency management, personnel, and

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