SECTION 5. REQUEST FOR

COMMENTS AND CONTACT INFORMATION

The Treasury Department and the IRS request comments on the rules described in this notice, including potential simplification of the rules described in section 3.02 of this notice through the establishment of multi-year PTEP accounts. The Treasury Department and the IRS also request comments concerning the following topics:

1. The extent to which basis created under section 961(c) should be treated as basis for purposes of determining tested income in applying section 951A;

2. The extent to which gain or loss, including foreign currency gain or loss, should be recognized by reason of distributions of PTEP. Additionally, the Treasury Department and the IRS request comments regarding a potential election pursuant to which the shareholder would agree to establish and maintain a multi-year section 951A PTEP group and not apply section 250(a)(2) to the extent such provision would otherwise be relevant in calculating its foreign currency gain or loss on a distribution of section 951A PTEP;

3. The application of sections 959 and 961 to domestic and foreign partnerships; and

4. Other guidance that should be issued under sections 959 and 961, including comments on the 2006 proposed regulations and the extent to which guidance in the 2006 proposed regulations should be incorporated into new proposed regulations. Comments should be submitted by February 12, 2019. Comments may be submitted electronically via the Federal eRulemaking Portal at www.regulations.gov (type IRS–2018–0041 in the search field on the regulations.gov homepage to find this notice and submit comments). Written comments may be submitted to the Office of Associate Chief Counsel (International), Attention: Melinda E. Harvey, Internal Revenue Service, IR–4579, 1111 Constitution Avenue, NW, Washington, DC 20224.

Comments will be available for public inspection and copying.

The principal author of this notice is Melinda E. Harvey of the Office of Associate Chief Counsel (International). For further information regarding this notice, contact Ms. Harvey at (202) 317-6934 (not a toll-free number).

2019 Standard Mileage Rates

Notice 2019–02