Documents

Compensatory Stock Options Under Section 482

Federal Register · Proposed Rule · Jul 29, 2002

restricted stock, nonstatutory stock options, statutory stock options (incentive stock options described in section 422(b) and options granted under an employee stock purchase plan described in section 423 … Solely for purposes of this paragraph (d)(2)(iii)(A), section 421 does not apply to the transfer of stock pursuant to the exercise of an option that meets the requirements of section 422(a) or 423(a).

Application of the Federal Insurance Contributions Act, Federal Unemployment Tax Act, and Collection of Income Tax at Source to Statutory Stock Options

Federal Register · Proposed Rule · Nov 14, 2001

U.S., 452 U.S. 247 (1981), that the definitions of wages for FICA and income tax withholding purposes were the same. … LoBue, 351 U.S. 243 (1956); Commissioner v. Smith, 324 U.S. 177 (1945).

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

Federal Register · Proposed Rule · Aug 29, 2005

U.S. Parent (USP), a U.S. corporation, and its foreign subsidiary (FS) enter a CSA in Year 1. … (i) U.S.

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

Federal Register · Proposed Rule · Jan 5, 2009

The temporary regulations provide guidance regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement. … This certification is based on the fact that this rule applies to U.S. businesses and foreign affiliates that enter into cost sharing agreements.

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles

Federal Register · Proposed Rule · Sep 10, 2003

In Year 1, FP enters the U.S. market by selling YY wristwatches to its newly organized U.S. subsidiary, USSub, for distribution in the U.S. market. … in the U.S. market.

Treatment of Certain Transfers of Property to Foreign Corporations

Federal Register · Proposed Rule · Sep 16, 2015

Coordination with Section 482 The temporary regulations under section 482 published in the Rules and Regulations section of this issue of the Federal Register clarify the coordination of the application … in accordance with section 482 and the regulations thereunder

Safe Harbor for Valuation Under Section 475

Federal Register · Proposed Rule · May 24, 2005

The safe harbor requires that financial statement values be adjusted to comply with the requirements of section 482 or section 482 principles when applicable. … of section 475 must be consistent with section 482.

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.

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

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.

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.

Reorganizations; Receipt of Securities

Federal Register · Proposed Rule · Dec 23, 1996

Southwest Consolidated Corp., 315 U.S. 194 (1942), with Raymond v. Commissioner, 37 B.T.A. 423 (1938).

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

Federal Register · Proposed Rule · Dec 11, 1995

of the natural resources determined at the export terminal should be the price charged by the producing member to the purchasing member for purposes of section 482. … under section 482

Guidance on Passive Foreign Investment Companies and the Treatment of Qualified Improvement Property Under the Alternative Depreciation System for Purposes of Sections 250(b) and 951A(d)

Federal Register · Proposed Rule · Jan 15, 2021

U.S. regulatory body. … United States, 491 U.S. 244, 248, n.2 (1989); Anchor National Life Ins. v. Commissioner, 93 T.C. 382, 423 (1989).

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

Federal Register · Proposed Rule · Sep 19, 2005

Space and Ocean Income of U.S. … Several commentators stated that allocation of gross income based on section 482 principles will be burdensome and expensive and will create uncertainty.

Section 367(d) Rules for Certain Repatriations of Intangible Property

Federal Register · Proposed Rule · May 3, 2023

In general, the U.S. transferor takes into account an annual inclusion over the useful life of the intangible property, as determined in accordance with the provisions of section 482 and regulations thereunder … In determining the amount of gross income that is attributable to a foreign branch that must be adjusted, the principles of sections 367(d) and 482 apply.

Additional Rules Regarding Base Erosion and Anti-Abuse Tax

Federal Register · Proposed Rule · Dec 6, 2019

This taxpayer's regular U.S. taxable income is $600x ($1000x + $500x − $870x − $30x), its regular U.S. tax rate is 21.0 percent, and its regular U.S. tax liability is $21x ($600x × 21% = $126x, less … In this example the total U.S. tax bill is $63x ($21x of regular tax and $42x of BEAT).

Source of Income From Certain Sales of Personal Property

Federal Register · Proposed Rule · Dec 30, 2019

U.S. … U.S.

Removal of Allocation Rule for Disbursements From Designated Roth Accounts to Multiple Destinations

Federal Register · Proposed Rule · Sep 19, 2014

Notice 2009-68, 2009-2 CB 423 (September 28, 2009), contains two safe harbor explanations that may be provided to recipients of eligible rollover distributions from an employer plan in order to satisfy … of Availability of IRS Documents The IRS notices cited in this preamble are published in the Internal Revenue Bulletin or Cumulative Bulletin and are available from the Superintendent of Documents, U.S

Guidance Regarding Charitable Remainder Trusts

Federal Register · Proposed Rule · Apr 18, 1997

No. 552, 91st Cong., 1st Sess. 87 (1969), 1969-3 C.B. 423, 479. … No. 552, 91st Cong., 1st Sess. 90 (1969), 1969-3 C.B. 423, 481.