Documents

Briefs, oral arguments, agency decisions and the Federal Register.

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  • PrivateFoundationsandCharitableTrusts,1996

    Agency decision · Agency decision

    In addition to domestic foundations, foreign organizations receiving certain degrees of support from U.S. citizens or corporations must also file Form 990-PF. … Like domestic foundations, organizations based in foreign countries are required to pay excise tax on their net investment income from U.S. sources.

    Internal Revenue Service
  • Bulletin No. 2023–22

    Agency decision · Agency decision

    Manufactured Product’s manufacturer to produce the U.S. Manufactured Product or by the Non-U.S. Manufactured Product’s manufacturer to produce or acquire the U.S. Component. … For purposes of this notice, the manufacturer of a U.S. Manufactured Product or a Non-U.S. Manufactured Product is the person that performed the manufacturing process that produced the U.S.

    Internal Revenue Service
  • Bulletin No. 2001–36

    Agency decision · Agency decision

    Section 482.—Allocation of Income and Deductions Among Taxpayers sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2001. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

    Internal Revenue Service
  • Bulletin No. 2021–10

    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.

    Internal Revenue Service
  • Bulletin No. 1997–45

    Agency decision · Agency decision

    Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of November 1997. See Rev. Rul. 97–44, page 5. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

    Internal Revenue Service
  • Bulletin No. 2025–19

    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, 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.

    Internal Revenue Service
  • Bulletin No. 2025–36

    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 1.6050K-1(f)(1) requires a partnership to file Form 8308 as an attachment to its Form 1065, U.S.

    Internal Revenue Service
  • SEQ 0001 JOB D37-001-005 PAGE-0003 COVER

    Agency decision · Agency decision

    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. … Further, income arising as a result of a secondary adjustment made in conjunction with a reallocation of income under section 482 from a foreign person to a related U.S. person is considered paid to a

    Internal Revenue Service
  • Application of Modified Carryover Basis to General Basis Rules

    Federal Register · Proposed Rule · May 11, 2015

    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

    80 FR 26873Treasury DepartmentInternal Revenue Service
  • Bulletin No. 2025–25

    Agency decision · Agency decision

    Effective Date Upon signature by the U.S. and Danish competent authorities, this Arrangement is effective for dividends paid on or after February 1, 2008. … -10, 2025-19 I.R.B. 1421 2025-11, 2025-23 I.R.B. 1451 2025-12, 2025-23 I.R.B. 1471 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

    Internal Revenue Service
  • Bulletin No. 2023–24

    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. … , 2023-23 I.R.B. 905 2023-43, 2023-24 I.R.B. 919 9970, 2023-2 I.R.B. 311 9771, 2023-3 I.R.B. 346 9772, 2023-11 I.R.B. 530 9773, 2023-11 I.R.B. 557 Proposed Regulations: REG-100442-22, 2023-3 I.R.B. 423

    Internal Revenue Service
  • Sole Proprietorship Returns, 2012

    Agency decision · Agency decision

    See U.S. Department of Commerce, Bureau of Economic Analysis, Survey of Current Business. … Constant dollars are based on the overall implicit price deflator for gross domestic product computed and reported by the U.S.

    Internal Revenue Service
  • Bulletin No. 2023–45

    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.

    Internal Revenue Service
  • Bulletin No. 2021–23

    Agency decision · Agency decision

    Continuation coverage elected under the FEHB program pursuant to 5 U.S. … June 7, 2021 Part IV U.S.

    Internal Revenue Service
  • Bulletin No. 2020–53

    Agency decision · Agency decision

    No additional production, U.S. source gross receipts. U.S. … U.S.

    Internal Revenue Service
  • Contributions in Exchange for State or Local Tax Credits

    Federal Register · Proposed Rule · Aug 27, 2018

    American Bar Endowment, 477 U.S. 105, 116-118 (1986). … United States, 449 F.2d 413, 422-423 (Ct. Cl. 1971); American Bar Endowment, 477 U.S. at 116-17 (citing Singer ); Hernandez v. Commissioner, 490 U.S. 680 (1989).

    83 FR 43563Treasury DepartmentInternal Revenue Service
  • Withdrawal of Guidance Under Subpart F Relating to Partnerships and Branches and Issuance of New Guidance Under Subpart F Relating to Certain Hybrid Transactions

    Federal Register · Proposed Rule · Jul 13, 1999

    IRS set forth a framework for dealing with issues arising under subpart F (sections 951 through 964) that relate to the use of certain entities that are regarded as fiscally transparent for purposes of U.S … by the Internal Revenue Service; or (6) A de minimis periodic adjustment by the parties to the arrangement made annually (or more frequently) to conform the payments to the requirements of section 482

    64 FR 37727Treasury DepartmentInternal Revenue Service
  • Municipal Bonds, 2010

    Agency decision · Agency decision

    U.S. … However, the money amounts add to the totals. [2] U.S. Possessions include Guam, Puerto Rico, and the U.S.

    Internal Revenue Service
  • Bulletin No. 2021–19

    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. … 2021-08, 2021-18 I.R.B. 1146 Notices: 2021-01, 2021-02 I.R.B. 315 2021-03, 2021-02 I.R.B. 316 2021-04, 2021-02 I.R.B. 319 2021-02, 2021-03 I.R.B. 478 2021-05, 2021-03 I.R.B. 479 2021-07, 2021-03 I.R.B. 482

    Internal Revenue Service
  • Bulletin No. 2022–31

    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.

    Internal Revenue Service

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