Federal Register/Vol. 84, No. 97/Monday, May 20, 2019/Proposed Rules

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Federal Register/Vol. 84, No. 97/Monday, May 20, 2019/Proposed Rules 22756 Federal Register / Vol. 84, No. 97 / Monday, May 20, 2019 / Proposed Rules rents, or royalties received or accrued (iii) Anti-abuse rule. Paragraphs § 1.958–2 Constructive ownership of from a foreign corporation as received or (f)(2)(iv)(B)(1) and (3) of this section stock. accrued from a controlled foreign apply to taxable years of controlled * * * * * corporation payor if a principal purpose foreign corporations ending on or after (d) * * * of the use of an option to acquire stock May 17, 2019, and to taxable years of (1) * * * Except as otherwise or an equity interest, or an interest United States shareholders in which or provided in paragraph (d)(2) of this similar to such an option, that causes with which such taxable years end, with section and § 1.954–1(f)— the foreign corporation to be a respect to amounts that are received or * * * * * controlled foreign corporation payor is accrued by a controlled foreign (e) * * * Except as otherwise to qualify dividends, interest, rents, or corporation on or after May 17, 2019 to provided in § 1.954–1(f), if any person royalties paid by the foreign corporation the extent the amounts are received or has an option to acquire stock, such for the section 954(c)(6) exception. For accrued in advance of the period to stock shall be considered as owned by purposes of this paragraph which such amounts are attributable such person. * * * (f)(2)(iv)(B)(2), an interest that is similar with a principal purpose of avoiding the * * * * * to an option to acquire stock or an application of paragraph (f)(2)(iv)(B)(1) (h) Applicability date. Paragraphs equity interest includes, but is not or (3) of this section with respect to limited to, a warrant, a convertible debt (d)(1) and (e) of this section apply for such amounts. taxable years of controlled foreign instrument, an instrument other than * * * * * debt that is convertible into stock or an corporations ending on or after the date ■ Par. 4. Section 1.954–2 is amended of publication in the Federal Register of equity interest, a put, a stock or equity by: interest subject to risk of forfeiture, and the Treasury decision adopting these ■ 1. Revising paragraphs (c)(2)(iii)(B) a contract to acquire or sell stock or an rules as final regulations, and for the and (c)(2)(iv)(A). taxable years of United States equity interest. ■ (3) Neither section 318(a)(4), nor 2. Revising the heading of paragraph shareholders in which or with which § 1.958–2(e) or the principles thereof, (i). such taxable years end. ■ 3. Redesignating paragraph (i)(2) as applies to treat a person that has an Kirsten Wielobob, option to acquire stock or an equity paragraph (i)(3). ■ 4. Adding new paragraph (i)(2). Deputy Commissioner for Services and interest, or an interest similar to such an Enforcement. The revisions and addition read as option, as owning the stock or equity [FR Doc. 2019–10464 Filed 5–17–19; 8:45 am] interest if a principal purpose for the follows: BILLING CODE 4830–01–P use of the option or similar interest is § 1.954–2 Foreign personal holding to treat a person as a related person with company income. respect to a controlled foreign DEPARTMENT OF LABOR corporation under this paragraph (f). For * * * * * purposes of this paragraph (c) * * * (2) * * * Occupational Safety and Health (f)(2)(iv)(B)(3), an interest that is similar Administration to an option to acquire stock or an (iii) * * * (B) Deductions for amounts (including equity interest includes, but is not 29 CFR Part 1910 limited to, a warrant, a convertible debt rents and royalties) paid or incurred by instrument, an instrument other than the lessor for the right to use the [Docket No. OSHA–2016–0013] property (or a component thereof) that debt that is convertible into stock or an RIN 1218–AD00 equity interest, a put, a stock or equity generated the rental income; interest subject to risk of forfeiture, and * * * * * The Control of Hazardous Energy a contract to acquire or sell stock or an (iv) * * * (Lockout/Tagout) equity interest. (A) Amounts (including rents and AGENCY: (3) Applicability dates—(i) General royalties) paid or incurred by the lessor Occupational Safety and Health rule. Except as otherwise provided in for the right to use the property (or a Administration (OSHA), DOL. this paragraph (f)(3), paragraph (f)(2)(iv) component thereof) that generated the ACTION: Request for Information (RFI). of this section applies to taxable years rental income; of controlled foreign corporations SUMMARY: The control of hazardous * * * * * ending on or after the date of energy is regulated under OSHA’s publication in the Federal Register of (i) Applicability dates. *** control of hazardous energy (Lockout/ the Treasury decision adopting these (2) Paragraphs (c)(2)(iii)(B) and Tagout) standard. The standard’s rules as final regulations, and taxable (c)(2)(iv)(A) of this section. Paragraphs purpose is to protect workers from the years of United States shareholders in (c)(2)(iii)(B) and (c)(2)(iv)(A) of this dangers of hazardous energy. This RFI which or with which such taxable years section apply for taxable years of seeks information regarding two areas end. controlled foreign corporations ending where modernizing the Lockout/Tagout (ii) Option rule in paragraph on or after the date of publication in the standard might better promote worker (f)(2)(iv)(B)(2) of this section. Paragraph Federal Register of the Treasury safety without additional burdens to (f)(2)(iv)(B)(2) of this section applies to decision adopting these rules as final employers: control circuit type devices taxable years of controlled foreign regulations, and for the taxable years of and robotics. OSHA’s Lockout/Tagout corporations beginning after December United States shareholders in which or standard currently requires that all 31, 2006, and ending before the date of with which such taxable years end. sources of energy, including energy publication in the Federal Register of * * * * * stored in the machine itself, be the Treasury decision adopting these ■ Par. 5. Section 1.958–2 is amended by controlled during servicing and rules as final regulations, and taxable revising paragraph (d)(1) introductory maintenance of machines and years of United States shareholders in text and the first sentence of paragraph equipment using an energy-isolating which or with which such taxable years (e) and adding paragraph (h) to read as device (EID). Control circuit type end. follows: devices are specifically excluded from VerDate Sep<11>2014 16:03 May 17, 2019 Jkt 247001 PO 00000 Frm 00019 Fmt 4702 Sfmt 4702 E:\FR\FM\20MYP1.SGM 20MYP1 khammond on DSKBBV9HB2PROD with PROPOSALS Federal Register / Vol. 84, No. 97 / Monday, May 20, 2019 / Proposed Rules 22757 OSHA’s definition of an EID and are that the Docket Office can attach them Communications; telephone: 202–693– thus not a compliant method of to the appropriate document. 1999; email: [email protected]. controlling hazardous energy during Regular mail, express mail, hand General and technical information: service and maintenance activities. But delivery, or messenger (courier) service: Lisa Long, OSHA Directorate of technological advances since the Submit comments and any additional Standards and Guidance; email: standard was issued in 1989 suggest material (for example, studies or journal [email protected]. that, at least in some circumstances, articles) to the OSHA Docket Office, SUPPLEMENTARY INFORMATION: control circuit type devices may be at Docket No. OSHA–2016–0013 or RIN Copies of this Federal Register notice: least as safe as EIDs. OSHA requests 1218–AD00, Technical Data Center, Electronic copies are available at information, data, and comments that Room N3653, Occupational Safety and https://www.regulations.gov. This would assist the agency in determining Health Administration, U.S. Department Federal Register notice, as well as news under what conditions control circuit of Labor, 200 Constitution Avenue NW, releases and other relevant information, type devices could safely be used for the Washington, DC 20210; telephone: (202) is also available at OSHA’s web page at control of hazardous energy. OSHA may 693–2350. (OSHA’s TTY number is https://www.osha.gov. also consider changes to the Lockout/ (877) 889–5627). All additional References and Exhibits (optional): Tagout standard that address hazardous materials must clearly identify your Documents referenced by OSHA in this energy control for new robotics electronic submission by name, date, RFI, other than OSHA standards and technologies. Employers are and docket number so that OSHA can Federal Register notices, are in Docket increasingly using robots and robotic attach them to your comments. Due to No. OSHA–2016–0013 (Lock-out/Tag- components in their workplaces. OSHA security procedures, there may be out Update). The docket is available at would like to know more about what delays in receiving materials that are https://www.regulations.gov, the Federal hazards and benefits this presents with sent by regular mail. For more eRulemaking Portal. For additional respect to control of hazardous energy, information about security procedures information on submitting items to, or safeguards that can be used, increased concerning the delivery of materials by accessing items in, the docket, please efficiencies that result, and any other express delivery, hand delivery, and refer to the ‘‘ADDRESSES’’ section of information related to ensuring messenger or courier service, please this RFI. Most exhibits are available at employee safety in interfacing with contact the OSHA Docket Office. The https://www.regulations.gov; some robots. OSHA will use the information hours of operation for the OSHA Docket exhibits (e.g., copyrighted material) are received in response to this RFI to Office are 10:00 a.m.
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