Documents

Investing in Qualified Opportunity Funds

Federal Register · Proposed Rule · May 1, 2019

and all section 482 regulations in this chapter) at the time that the lease was entered into; and ( 3 ) Additional requirements for leases from a related person. … P, S, and Q are members of a U.S. consolidated group (P group). In 2018, S sells an asset to an unrelated party and realizes $500 of capital gain.

Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Private Equity Funds

Federal Register · Proposed Rule · Feb 28, 2020

Initial recordkeeping burdens: (10 hours) × (255 entities) × (Attorney at $423 per hour) = $1,078,650. 339  Annual recordkeeping burdens: (10 hours) × (255 entities) × (Attorney at $423 per hour … ) × (26 disclosures per year) × (Attorney at $423 per hour) = $1,402,245.

Recognition and Deferral of Section 987 Gain or Loss

Federal Register · Rule · May 13, 2019

On January 17, 2017, the Treasury Department and the IRS published Notice 2017-07, 2017-3 I.R.B. 423, announcing that certain rules under § 1.987-12T would be modified to prevent potential abuse by taxpayers … . person, the potential successor QBU is owned by a U.S. person.

Prehispanic Artifacts From El Salvador

Federal Register · Rule · Mar 10, 1995

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.).

Agency Information Collection Activities: Information Collection Renewal; Comment Request; CRA Information Collection Survey

Federal Register · Notice · Dec 15, 2020

• For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … “The Consequences of Mortgage Credit Expansion: Evidence from the U.S.

Application of Section 409A to Nonqualified Deferred Compensation Plans

Federal Register · Proposed Rule · Oct 4, 2005

However, with respect to U.S. citizens working abroad, and with respect to resident aliens in the United States, compensation income generally is subject to U.S. … U.S. , 58 Fed. Cl. 507 (2003); § 31.3121(v)(2)-1(b)(4)(iv).

Proposed Agency Information Collection Activities; Comment Request

Federal Register · Notice · Jan 26, 2024

• For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … Additionally, commenters may send a copy of their comments to the OMB desk officers for the agencies by mail to the Office of Information and Regulatory Affairs, U.S.

Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m)

Federal Register · Rule · Dec 30, 2020

Assuming the partnership is respected for U.S. … Corporation T wishes to access the U.S. capital markets. Corporation T incorporates Corporation U, a wholly-owned subsidiary, in the U.S. to issue debt securities.

Section 30D New Clean Vehicle Credit

Federal Register · Proposed Rule · Apr 17, 2023

The CMA was concluded in the context of an earlier trade agreement the United States concluded with Japan in 2019, 2 a related 2019 agreement on digital trade, 3 and the U.S. … -Japan Partnership on Trade announced in November 2021. 4 The Treasury Department and the IRS have consulted with the U.S.

Proposed Agency Information Collection Activities; Comment Request

Federal Register · Notice · Apr 19, 2019

• For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … Additionally, commenters may send a copy of their comments to the OMB desk officer for the agencies by mail to the Office of Information and Regulatory Affairs, U.S.

Hedging Transactions

Federal Register · Rule · Mar 20, 2002

that is real property or property subject to depreciation; (3) certain copyrights (or similar property); (4) accounts or notes receivable acquired in the ordinary course of a trade or business; and (5) U.S … In addition, no implication is intended as to what constitutes “risk management” or “managing risk” for purposes of proposed or final regulations under section 482.

Technical Corrections Regarding Customs Organization

Federal Register · Rule · Sep 27, 1995

Vilders, Attorney, Regulations Branch (202) 482-6930. … Users Fee Task Force, Office of Finance, U.S. Customs Service, U.S.

Conduit Arrangements Regulations

Federal Register · Uncategorized Document · Oct 14, 1994

(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. … (ii) Under the country Y-U.S. income tax treaty, the royalties paid by DS to FS are exempt from U.S. withholding tax.

Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups

Federal Register · Proposed Rule · Dec 17, 2019

Appropriate economic analyses, based on the principles of section 482, must be used to estimate gross receipts. See paragraph (g)(5)(B)( 3 )( ii ) of this section ( Example 5 ). … However, a reasonable estimate of Z's gross receipts attributable to the floodlights, based on the principles of section 482, is $120,000x.

Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

Federal Register · Rule · Jul 15, 2020

Intermediate Sales to a U.S. … made to the U.S. government.

Role of Supervisory Guidance

Federal Register · Proposed Rule · Nov 5, 2020

Mortgage Bankers Ass'n, 575 U.S. at 97 ( citing Shalala v. Guernsey Memorial Hospital, 514 U.S. 87, 99 (1995)). … Clearing House Assn L.L.C., 557 U.S. 519 (2009); United States v. Gaubert, 499 U.S. 315 (1991); and United States v. Philadelphia Nat. Bank, 374 U.S. 321 (1963).

General Revision of Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Related Collection, Refunds, and Credits; Revision of Information Reporting and Backup Withholding Regulations; and Removal of Regulations Under Part 35a and of Certain Regulations Under Income Tax Treaties

Federal Register · Rule · Oct 14, 1997

(2) Income allocated under section 482. A payment is considered made to the extent income subject to withholding is allocated under section 482. … 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

Inbound Grantor Trusts With Foreign Grantors

Federal Register · Rule · Aug 10, 1999

of U.S. tax. … In addition, commenters pointed out that there already are other provisions, such as sections 482 and 845, that apply to related-party reinsurance arrangements.

Subchapter K Anti-Abuse Rule

Federal Register · Rule · Jan 3, 1995

In determining whether a transaction clearly reflects the partners' income, the principles of sections 446(b) and 482 apply. … The CFC rules prevent the deferral by U.S. shareholders of U.S. taxation of certain earnings of the CFC and reduce disparities that otherwise might occur between the amount of income subject to a particular

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

Federal Register · Proposed Rule · Apr 10, 2026

, or U.S. … fewer, less complex SAR filings. 481 Table 8 presents this distribution, which results in a weighted annual average of 190 filings per PPSI, resulting in an annual burden of 285 hours per PPSI. 482