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

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  • Bulletin No. 1998–17

    Agency decision · Agency decision

    to the U.S. owners and U.S. beneficiaries in accordance with this announcement. … for failure to timely file if a foreign trust files its 1997 Form 3520–A with the Philadelphia Service Center and furnishes the required statements to the U.S. owners and U.S. beneficiaries by the later

    Internal Revenue Service
  • Income Attributable to Domestic Production Activities

    Federal Register · Proposed Rule · Nov 4, 2005

    The IRS and Treasury Department further believe that the reference to section 482 principles in footnote 27 of the Conference Report reflects an intent to apply section 482 principles consistently … Comm'r , 326 U.S. 599 (1946)).

    70 FR 67220Treasury DepartmentInternal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … Proc. 91-14, 1991-1 C.B. 482 (checklist questionnaire).

    Internal Revenue Service
  • Bulletin No. 2024–25

    Agency decision · Agency decision

    A, a U.S. … C, a U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    that about 60 percent of vehicles sold in the U.S. undergo U.S. final assembly. … Of new vehicles sold, share with U.S. final assembly 60 percent 4.

    Internal Revenue Service
  • Bulletin No. 2021–11

    Agency decision · Agency decision

    Question 4: Are employers in U.S. Territories eligible for the employee retention credit? Answer 4: Yes. If an employer in a U.S. … Payments of wages by employers in U.S. Territories are wages within the meaning of section 3121(a). Accordingly, eligible employers include employers in the U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … . possessions, and other matters relating to the activities of non-U.S. persons within the United States or U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … . possessions, and other matters relating to the activities of non-U.S. persons within the United States or U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … . possessions, and other matters relating to the activities of non-U.S. persons within the United States or U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … . possessions, and other matters relating to the activities of non-U.S. persons within the United States or U.S.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    It also serves U.S. citizens and residents with offshore activities and non-residents with U.S. activities. … . territories, and other matters relating to the activities of non-U.S. persons within the United States or U.S.

    Internal Revenue Service
  • Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities

    Federal Register · Rule · Jan 28, 2013

    For purposes of this paragraph (a)(4)(i), a withholding agent is related to the payee or beneficial owner if it is related within the meaning of section 482. … The following rules also apply for purposes of this paragraph (a)(2)(vii)(B): §§ 1.1441-2(e)(2) (regarding when a payment is considered made in the case of income allocated under section 482); 1.1441-2

    78 FR 5874Treasury DepartmentInternal Revenue Service
  • SEQ 0001 JOB B09-001-006 PAGE-0003 COVER

    Agency decision · Agency decision

    For sale by the Superintendent of Documents U.S. … Proc. 92–56 (1992–2 C.B. 409), ‘‘The Relationship between U.S.

    Internal Revenue Service
  • Bulletin No. 2020–34

    Agency decision · Agency decision

    U.S., 105 Fed. … Section 263A August 17, 2020 U.S. Return of Partnership Income or Form 1120-S, U.S.

    Internal Revenue Service
  • Rules Regarding Certain Hybrid Arrangements

    Federal Register · Rule · Apr 8, 2020

    U.S. shareholder). … (A) Under U.S. tax law, the payment is imputed (for example, under section 482 or 7872, including because the instrument pursuant to which it is made is indebtedness but the terms of the instrument provide

    85 FR 19802Treasury DepartmentInternal Revenue Service
  • Do Financial Frictions Amplify Fiscal Policy? Evidence

    Agency decision · Agency decision

    In the top three deciles are: professional, scientific and technical services (541), specialty trade contractors (238), computer and electronic product manufacturing (334), durable goods wholesalers (423 … U.S. House of Representatives. Cooper, Russell, and John Haltiwanger. 2006. “On the Nature of Capital Adjustment Costs.” Review of Economic Studies, 73(3): 611–633. Cummins, Jason G., Kevin A.

    Internal Revenue Service
  • Bulletin No. 2026–39

    Agency decision · Agency decision

    that about 60 percent of vehicles sold in the U.S. undergo U.S. final assembly. … For this purpose, regulations under section 1248 provide rules for 423 determining E&P attributable to stock in a foreign corporation in simple and complex cases. See §§1.1248-2 and 1.12483.

    Internal Revenue Service
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    Proc. 92–29, 1992–1 C.B. 748. 482 Advance pricing agreements Rev. … Rul. 54–482, 1954–2 C.B. 148 (old common stock exchanged for new common stock).

    Internal Revenue Service
  • Private Foundations and Charitable Trusts: A Decade of Charitable

    Agency decision · Agency decision

    'A greater per-income from U.S. sources only. … U.S. and State Government obligations.........................................................

    Internal Revenue Service
  • Purchase Price Allocations in Deemed Actual Asset Acquisitions

    Federal Register · Proposed Rule · Aug 10, 1999

    220), qualified pension, profit-sharing, stock bonus and annuity plans (sections 401(a) and 403(a)), simplified employee pensions (section 408(k)), tax qualified stock option plans (sections 422 and 423 … Commissioner, 344 U.S. 6 (1952).

    64 FR 43462Proposed RuleTreasury Department

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