Documents

Bulletin No. 2023–19

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. … 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 2023. See Rev.

Allocation and Sourcing of Income and Deductions Among Taxpayers Engaged in a Global Dealing Operation

Federal Register · Proposed Rule · Mar 6, 1998

Section 482 concerns the allocation of income, deductions, credits and allowances among related parties. … The addition and revision read as follows: Sec. 1.482-0 Outline of regulations under section 482.

Computation of Combined Taxable Income Under the Profit Split Method When the Possession Product Is a Component Product or an End- Product Form

Federal Register · Uncategorized Document · Jan 12, 1994

The proposed change is intended to simplify the computation of combined taxable income under Q & A. 12 and to eliminate the need to apply section 482 in cases in which a possession product is a component … -- (A) First, to U.S. affiliates (other than tax-exempt affiliates) within the group (as determined under section 482) which derive income with respect to the product produced in whole or in part in

Apportionment of Tax Items Among the Members of a Controlled Group of Corporations

Federal Register · Rule · Dec 28, 2009

Rose, 286 U.S. 319 (1932). … Life Insurance Company Income Tax Return,” where the common parent is a life insurance company; a Form 1120-PC, “U.S.

Partner's Distributive Share

Federal Register · Proposed Rule · Nov 18, 2005

substantiality of an allocation under section 704(b) where the partners are look-through entities or members of a consolidated group, provide additional guidance on the effect of other provisions, such as section 482 … to those situations in which the controlled foreign corporation owns greater than a threshold minimum percentage interest in the partnership, or only by taking into account the tax attributes of those U.S

Department of the Treasury (2019)

Agency decision · Agency decision

. • Imported drugs not approved by the U.S. Food and Drug Administration (FDA). This includes foreign-made versions of U.S. … U.S. possession taxes. Include taxes imposed by a U.S. possession with your state and local taxes on lines 5a, 5b, and 5c.

Exclusions From Gross Income of Foreign Corporations

Federal Register · Rule · Aug 8, 2005

Need for Change Pursuant to section 423 of the American Jobs Creation Act of 2004, (118 Stat. 1418, 2004), Public Law 108-357 (AJCA), the applicability date of the final regulations under section 883 … For taxable years of the foreign corporation beginning after September 24, 2004, and until such time as the Form 1120-F, “U.S.

Safe Harbor for Valuation Under Section 475.

Federal Register · Rule · Jun 12, 2007

For example, if a notional principal contract is subject to section 482 or section 482 principles, the values of future cash flows taken into account in determining the value of the contract for purposes … of section 475 must be consistent with section 482.

Tax-ExemptPrivateActivityBonds,1988-1995

Agency decision · Agency decision

U.S. Possessions Other Than Puerto Rico.— The Virgin Islands, Guam, and the Northern Mariana Islands comprise this category in Tables 5 and 6. … ................. -36 Maine....................................................................................................................... -77 238 -** 130 207 --** --- 317 331 508 696 151 423

Property Transferred in Connection With the Performance of Services Under Section 83

Federal Register · Proposed Rule · May 30, 2012

Bull. 423, 501). … No. 91-552, 1969-3 CB 423, 500. See also H. Rep. No. 91-413, 1969-3 CB 200, 254.

Bulletin No. 2021–14

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. 2025–15

Agency decision · Agency decision

Parent & Subsidiary Non-U.S. 37% Subsidiary 37% Non-U.S. Parent & U.S. Subsidiary Non-U.S. Parent & 56% U.S. … between non-U.S. and U.S. subsidiaries.

Allocation and Sourcing of Income and Deductions Among Taxpayers Engaged in a Global Dealing Operation; Correction

Federal Register · Proposed Rule · Apr 21, 1998

sourcing of income, deductions, gains and losses from a global dealing operation; rules applying these allocation and sourcing rules to foreign currency transactions and to foreign corporations engaged in a U.S … SUPPLEMENTARY INFORMATION: Background The notice of proposed rulemaking that is subject to these corrections is under sections 482 and 864 of the Internal Revenue Code.

Source of Income From Sales of Inventory and Natural Resources Produced in One Jurisdiction and Sold in Another Jurisdiction

Federal Register · Rule · Nov 29, 1996

under section 482 … U.S. Mines, a U.S. corporation, operates a copper mine and mill in country X. U.S.

Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest

Federal Register · Rule · Jan 14, 2025

Humana, 525 U.S. at 310. … Fabe, 508 U.S. at 491-92 ( citing SEC v. Nat'l Sec., Inc., 393 U.S. at 460).

Treatment of Certain Transfers of Property to Foreign Corporations

Federal Register · Rule · Dec 16, 2016

(including temporary regulations under section 482 issued with the proposed regulations (see § 1.482-1T(f)(2)(i), TD 9738, 80 FR 55538). … in accordance with section 482 and the regulations thereunder

Bulletin No. 2021–36

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. … connected gain or loss and, therefore, is subject to U.S. tax.

Source of Income From Certain Space and Ocean Activities; Source of Communications Income

Federal Register · Rule · Dec 27, 2006

carry a foreign-to-U.S. or U.S. … U.S.

Proposed Collection; Comment Request for Forms 1065, 1066, 1120, 1120-C, 1120-F, 1120-H, 1120-ND, 1120-S,1120-SF,1120-FSC,1120-L,1120-PC,1120-REIT,1120-RIC,1120-POL, and Related Attachments

Federal Register · Notice · Sep 17, 2021

Form 1120-POL U.S. Income Tax Return for Certain Political Organizations. Form 1120-REIT U.S. Income Tax Return for Real Estate Investment Trusts. Form 1120-RIC U.S. … Form 8288 * U.S. Withholding Tax Return for Dispositions by Foreign Persons of U.S. Real Property Interests.

Proposed Collection; Comment Request for Forms 1065, 1066, 1120, 1120-C, 1120-F, 1120-H, 1120-ND, 1120-S, 1120-SF, 1120-FSC, 1120-L, 1120-PC, 1120-REIT, 1120-RIC, 1120-POL, and Related Attachments

Federal Register · Notice · Sep 30, 2019

Interest in a Foreign Partnership Changes. 75 1545-1647 * Revenue Procedure 2001-21 Debt Roll-Ups. 1,620 1545-1657 * Revenue Procedure 99-32—Conforming Adjustments Subsequent to Section 482 … Treasury Grants for Specified Energy Property in Lieu of Tax Credits. 300,000 1545-2147 Internal Revenue Code Section 108(i) Election. 4,500 1545-2149 Treatment of Services Under Section 482