Documents

Agency Information Collection Activities; Submission for OMB Review; Comment Request

Federal Register · Notice · Nov 23, 2020

Branches and Agencies of Foreign Banks (FFIEC 002) and the Report of Assets and Liabilities of a Non-U.S. Branch that is Managed or Controlled by a U.S. Branch or Agency of a Foreign (Non-U.S.) … • For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340.

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).

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

Violations of Laws or Regulations

Federal Register · Proposed Rule · Sep 1, 2026

Clearing House Ass'n, 557 U.S. 519 (2009); United States v. Gaubert, 499 U.S. 315 (1991); United States v. Phila. … See footnote 8 of the U.S. Small Business Administration's Table of Size Standards.

Treatment of Payments to Charitable Entities in Return for Consideration

Federal Register · Proposed Rule · Dec 17, 2019

Rul. 67-246, 1967-2 C.B. 104); Hernandez, 490 U.S. at 691 (citing Singer ). … Singer, 449 F.2d at 423-24.

Technical Corrections Regarding Customs Organization

Federal Register · Rule · Sep 27, 1995

Vilders, Attorney, Regulations Branch (202) 482-6930. … The New Orleans unit processes and liquidates vessel repair entries filed at ports on the Atlantic Coast of the U.S. from Norfolk, Virginia, southward, and all U.S. ports on the Gulf of Mexico, including

Classification of Digital Content Transactions and Cloud Transactions

Federal Register · Rule · Jan 14, 2025

may offset U.S. tax on the income from low-tax jurisdictions. … As a result, under paragraph (f)(2)(ii) of this section, the sale is treated as occurring at the location of Corp A and the income derived by Corp C from the sale is U.S. source.

Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance

Federal Register · Rule · Aug 30, 2000

Smith , 525 U.S. 459 (1999). … It also should be noted that the U.S.

Mid-contract Change in Taxpayer

Federal Register · Proposed Rule · Feb 16, 2001

These cases generally relied on section 446(b), section 482 and/or the assignment of income doctrine to allocate income to the transferor. See e.g., Jud Plumbing and Heating, Inc. v. … Commissioner, 190 F.2d 330 (10th Cir.), cert. denied, 342 U.S. 860 (1951); Central Cuba Sugar Co. v.

Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Risk Management

Federal Register · Proposed Rule · Jun 24, 2026

See footnote 8 of the U.S. Small Business Administration's Table of Size Standards. … The authority citation for part 4 continues to read as follows: Authority: 5 U.S.C. 301, 552; 12 U.S.C. 1, 93a, 161, 481, 482, 484(a), 1442, 1462a, 1463, 1464, 1817(a), 1818, 1820, 1821, 1831m,

Archaeological and Ethnological Material From Peru

Federal Register · Rule · Jun 11, 1997

FOR FURTHER INFORMATION CONTACT: Legal Aspects: Donnette Rimmer, Intellectual Property Rights Branch (202) 482-6960. … U.S. acceptance of the 1970 UNESCO Convention was codified into U.S. law as the ``Convention on Cultural Property Implementation Act'' (Pub.L. 97- 446, 19 U.S.C. 2601 et seq.) (``the Act'').

Application of Section 409A to Nonqualified Deferred Compensation Plans

Federal Register · Rule · Apr 17, 2007

of section 423. … U.S. for which they are compensated.

Conduit Arrangements Regulations

Federal Register · Rule · Aug 11, 1995

The same commentator further suggested that a person under common control within the meaning of section 482 should not be a related person for purposes of this regulation. … (v) Related means related within the meaning of sections 267(b) or 707(b)(1), or controlled within the meaning of section 482, and the regulations under those sections.

Allocation and Apportionment of Research and Experimental Expenditures

Federal Register · Rule · Dec 22, 1995

Proc. 92-56 (1992-2 C.B. 409), ``The Relationship Between U.S. … In 1996, X's gross income is $160,000, of which $140,000 is U.S. source income from domestic sales of gasoline engines and $10,000 is foreign source royalties from Y, and $10,000 is U.S. source interest

Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

Federal Register · Proposed Rule · Sep 11, 2026

. shareholder's R&E expenditures) for which the U.S. shareholder is not required to be fully compensated under section 482 principles. … (c) Reallocation to U.S. source income.

Inversions and Related Transactions

Federal Register · Rule · Apr 8, 2016

The 2014 notice defines a U.S. … a) U.S. shareholder

Companies Holding Certificates of Authority as Acceptable Sureties on Federal Bonds and as Acceptable Reinsuring Companies

Federal Register · Notice · Jun 30, 1995

Other information pertinent to Federal sureties may be obtained from the U.S. … In addition, Swiss Reinsurance Company, U.S.

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

Federal Register · Rule · Oct 10, 2024

A “repatriation” denotes a subsequent transfer of intangible property to the U.S. transferor or a United States person (U.S. person) related to the U.S. transferor. … (4) Coordination with section 482. For further guidance, see § 1.367(d)-1T(g)(4) (5) Determination of fair market value. For further guidance, see § 1.367(d)-1T(g)(5).

Retail Foreign Exchange Transactions

Federal Register · Proposed Rule · Apr 22, 2011

The major currencies currently are the U.S. … Additionally, you should send a copy of your comments to the OMB Desk Officer, by mail to U.S.

Retail Foreign Exchange Transactions

Federal Register · Rule · Jul 14, 2011

The commenter responded that there is no U.S. policy interest in applying U.S. consumer protection rules to transactions with non-U.S. residents conducted by foreign branches. … The major currencies currently are the U.S.