Prop. Treas. Reg. § 48.4101-1 Taxable fuel; registration.

Proposed 2026-02-04 · REG-121244-23 · 91 FR 5160 · Interprets § 4101 · Would amend § 48.4101-1

Par. 9. Section 48.4101-1 is amended by adding paragraphs (a)(7) and (8), and (l)(6), to read as follows:

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(a) * * *

(7) A letter of registration is not a determination of liability for tax, eligibility for a tax credit or deduction, or any other tax treatment under the Code. For example, a registration letter issued under activity letter SA to a person producing or importing a fuel that may be eligible for a credit under section 6426(k) of the Code is not a determination that such fuel qualifies for the section 6426(k) credit. A letter of registration is also not a determination letter, as defined in § 601.201(a)(3) of this chapter. The terms letter of registration and registration letter as used in this section have the same meaning as the term Letter of Registration as defined in § 1.4101-1(b)(2) of this chapter.

(8) A person is required to reregister under this section if after a transaction (or series of related transactions) more than 50 percent of ownership interests in, or assets of, such person are held by persons other than persons (or persons related thereto) who held more than 50 percent of such interests or assets before the transaction (or series of related transactions). Reregistration does not apply to any company whose stock is regularly traded on an established securities market. If a registrant changes its employer identification number (EIN), such registrant must reregister under this section using its new EIN.

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(l) * * *

(6) Paragraphs (a)(7) and (8) of this section apply to taxable years ending on or after [date of publication of final regulations in the Federal Register ].