Documents

Bulletin No. 1997–43

Agency decision · Agency decision

A c c o r d i n g l y, U.S. source effectively connected income of foreign taxpayers and U.S. source income of U.S. taxpayers will be treated the same. … However, the U.S.

Bulletin No. 2026–19

Agency decision · Agency decision

.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7702, 7872.) Rev. … Section 482.—Allocation of Income and Deductions Among Taxpayers The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2026. See Rev.

Bulletin No. 2025–22

Agency decision · Agency decision

PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul. … 2025-8, 2025-15 I.R.B. 1390 2025-9, 2025-16 I.R.B. 1415 2025-10, 2025-19 I.R.B. 1421 Treasury Decisions: 10016, 2025-3 I.R.B. 313 10020, 2025-3 I.R.B. 408 10018, 2025-4 I.R.B. 446 10019, 2025-4 I.R.B. 482

Bulletin No. 2025–23

Agency decision · Agency decision

.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.

Bulletin No. 1997–10

Agency decision · Agency decision

[Reserved]. (9) Effect of section 482 adjustments on post-1986 foreign income taxes and post-1986 undistributed earnings. [Reserved]. … For example, if an audit results in an allocation of income under section 482, and such allocation results in an adjustment treated as a capital contribution by a U.S. transferor to a foreign corporation

Including the instructions for (2023)

Agency decision · Agency decision

Was your qualifying relative a U.S. citizen, U.S. national, or U.S. resident alien? (See Pub. 519 for the definition of a U.S. national or a U.S. resident alien. … 403 408 413 418 423 403 408 413 418 423 403 408 413 418 423 7,000 7,050 7,100 7,150 7,200 7,050 7,100 7,150 7,200 7,250 703 708 713 718 723 703 708 713 718 723 703 708 713 718 723 703 708 713

A Comprehensive Strategy for Reducing the Tax Gap

Agency decision · Agency decision

A Comprehensive Strategy for Reducing the Tax Gap U.S. … A representative sample of these items includes: • Guidance regarding transfer-pricing arrangements involving cost-sharing under section 482; • Guidance under section 671 regarding information reporting

Treatment of Certain Interests in Corporations as Stock or Indebtedness

Federal Register · Rule · Oct 21, 2016

Alternatively, some comments suggested relocating the proposed documentation rules under sections 6662 or 482. … over U.S.

General Revision of Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Related Collection, Refunds, and Credits; Revision of Information Reporting and Backup Withholding Regulations; and Removal of Regulations Under Part 35a and of Certain Regulations Under Income Tax Treaties

Federal Register · Proposed Rule · Apr 22, 1996

Under paragraph (e)(2), income reallocated under section 482 from a U.S. person to a related foreign person would be considered a payment for withholding tax purposes. … (2) Income allocated under section 482. A payment is considered made to the extent income subject to withholding is allocated under section 482.

Bulletin No. 2026–28

Agency decision · Agency decision

Section 482.—Allocation of Income and Deductions Among Taxpayers Section 483. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.

Application of Modified Carryover Basis to General Basis Rules

Federal Register · Rule · Jan 19, 2017

share is subject to the adjustments provided by paragraphs (c)(4)(i)( b ) and ( c ) of this section, but such adjustments are only applicable in the case of an option that is subject to section 423 … For U.S. transferor decedents dying in 2010, the general rule of gain recognition under § 1.684-1 shall apply to any transfer of property by reason of death of the U.S. transferor if the basis of the property

Bulletin No. 2021–44

Agency decision · Agency decision

.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … The notice that must be submitted to DOL should be sent to the following address: U.S.

Bulletin No. 2021–18

Agency decision · Agency decision

.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … The security-required person must enter into a binding agreement with a U.S. agent (as defined in paragraph (d)(4)(ii)(D) of this section) authorizing the U.S. agent to act as an agent (U.S. agent agreement

A History of the Tax-Exempt Sector:

Agency decision · Agency decision

NOTES: Data were adjusted based on the chain-type price index for Gross Domestic Product as reported by the U.S. … 1998 46,208 7,585 6,484 1,100 1,670 569 506 464 1999 42,151 7,722 6,835 887 1,485 598 423 422 2000 38,567 8,413 7,703 710 1,427 717 406 403 2001 35,540 7,900 7,883 18

Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A

Federal Register · Rule · Nov 12, 2020

For purposes of the preceding sentence, a reasonable estimate based on the principles of section 482 must be made. See paragraph (g)(4)(ii)(B)( 3 ) of this section ( Example 4 ). … However, a reasonable estimate of Z's gross receipts attributable to the floodlights, based on the principles of section 482, is $120,000x.

Guidance on Passive Foreign Investment Companies

Federal Register · Proposed Rule · Jul 11, 2019

Such strategies erode the U.S. tax base, and reflect inefficient investment incentives for U.S. taxpayers. … Individual Income Tax Return), (U.S. Income Tax Return for Estates and Trusts), 1065 (U.S. Return of Partnership Income), 1120 (U.S.

Trends in Book-Tax Income and Balance Sheet Differences

Agency decision · Agency decision

The U.S. … Resources Comm., Tech. & Media Total 5,552 4,379 7,849 6,361 3,890 28,031 1990 262 342 304 258 231 1,397 1991 291 375 486 437 306 1,895 1992 314 393 539 498 328 2,072 1993 561 423

Bulletin No. 2025–32

Agency decision · Agency decision

.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … Section 482.—Allocation of Income and Deductions Among Taxpayers The applicable federal short-term, mid-term, and long-term rates are set forth for the month of August 2025. See Rev.

These synopses are intended only as aids to the reader in

Agency decision · Agency decision

For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. 2000–9 I.R.B. … 311 353 394 437 480 521 564 606 648 690 763 869 975 1,080 1,237 1,449 1,660 1,870 2,080 2,292 2,503 2,713 2,923 3,134 3,346 3,556 3,766 3,977 4,189 32 57 82 107 133 157 183 209 234 259 284 310 335 373 423

Instructions for Form

Agency decision · Agency decision

Enter the U.S. … Enter 50% of the freight expenses (except insurance) for shipping export property aboard U.S. flagships and U.S.-owned and U.S.