Documents

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

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  • Corporate Alternative Minimum Tax Applicable After 2022

    Federal Register · Proposed Rule · Sep 13, 2024

    and the regulations under section 482, regardless of whether section 482 otherwise is considered to apply. … For rules regarding adjustments to AFSI to reflect the principles of section 482 of the Code and the regulations under section 482, see § 1.56A-26(d).

    89 FR 75062Treasury DepartmentInternal Revenue Service
  • Section 45X Advanced Manufacturing Production Credit

    Federal Register · Proposed Rule · Dec 15, 2023

    (For purposes of this document, the term “U.S. territory” has the meaning of the term “possession” as defined in section 638(2).) … After consulting with experts at the Department of Energy, U.S.

    88 FR 86844Treasury DepartmentInternal Revenue Service
  • Temporary Asset Thresholds

    Federal Register · Rule · Dec 2, 2020

    FR Y-11 (annual)—Financial Statements of U.S. Nonbank Subsidiaries of U.S. … Report Title: Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies and Abbreviated Financial Statements of U.S Nonbank Subsidiaries of U.S.

    85 FR 77345Treasury DepartmentComptroller of the Currency
  • Agency Information Collection Activities; Submission for OMB Review; Comment Request

    Federal Register · Notice · Jan 27, 2020

    • For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … All notional amounts reported in Schedule RC-L should be based on the U.S. GAAP notional amount.

    85 FR 4780Treasury DepartmentComptroller of the Currency
  • Rules for Determining the Country of Origin of a Good for Purposes of Annex 311 of the North American Free Trade Agreement; Rules of Origin Applicable to Imported Merchandise

    Federal Register · Proposed Rule · May 5, 1995

    FOR FURTHER INFORMATION CONTACT: Sandra Gethers, Office of Regulations and Rulings (202-482-6980). … U.S., 681 F.2d 778 (CCPA 1982).

    60 FR 22312Treasury DepartmentCustoms Service
  • Unsafe or Unsound Practices, Matters Requiring Attention

    Federal Register · Rule · Sep 1, 2026

    Clearing House Ass'n, L.L.C., 557 U.S. 519 (2009); United States v. Gaubert, 499 U.S. 315 (1991); United States v. Phila. Nat'l Bank, 374 U.S. 321 (1963). … Garland, 596 U.S. 328, 346 (2022) (citing Niz-Chavez v. Garland, 593 U.S. 155, 171 (2021) and Jay v. Boyd, 351 U.S. 345, 357 (1956)).

    91 FR 56004Treasury DepartmentComptroller of the Currency
  • Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Jobs Act

    Federal Register · Proposed Rule · Dec 7, 2018

    The proposed regulations further require that the amount of any adjustment under the disregarded payment provisions must be determined under the arm's length principle of section 482 and the regulations … In determining the amount of gross income that is attributable to a foreign branch that must be adjusted by reason of this paragraph (f)(2)(vi)(D), the principles of sections 367(d) and 482 apply.

    83 FR 63200Treasury DepartmentInternal Revenue Service
  • Continuation Coverage Requirements Applicable to Group Health Plans

    Federal Register · Rule · Jan 10, 2001

    NLRB, 482 U.S. 27 (1987); EEOC v. … The U.S.

    66 FR 1843Treasury DepartmentInternal Revenue Service
  • Agency Information Collection Activities: Submission for OMB Review; Joint Comment Request

    Federal Register · Notice · Apr 11, 2018

    • For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … RC-A 2.b Balances due from other commercial banks in the U.S. and other depository institutions in the U.S.

    83 FR 15678Treasury DepartmentComptroller of the Currency
  • Limitations on the Importation of Net Built-In Losses

    Federal Register · Rule · Mar 28, 2016

    The facts are the same as in paragraph (i)(A) of this Example 1 except that FC is engaged in a U.S. trade or business and A3 is used in that U.S. trade or business. … (iii) FC's property used in U.S. trade or business. (A) Facts.

    81 FR 17066Treasury DepartmentInternal Revenue Service
  • Qualification Requirements for Transactions in Certain Securities

    Federal Register · Proposed Rule · Dec 30, 1996

    See U.S. General Accounting Office, Report to Congressional Requesters: Bank Mutual Funds Sales Practices and Regulatory Issues GAO/GGD-95-210, at p. 52 (September 1995); U.S. … Cir. 1979), cert. denied, 449 U.S. 823; see also National Petroleum Refiners Assoc. v. FTC, 482 F.2d 672, 680-81 (D.C.

    61 FR 68824Qualification Requirements for Transactions in Certain Securities,Justice Department
  • Base Erosion and Anti-Abuse Tax

    Federal Register · Rule · Oct 9, 2020

    in connection with a U.S. trade or business. … (B) U.S.-booked liabilities determination. (C) U.S.-booked liabilities in excess of U.S.-connected liabilities. (D) Election to use financial statements. (E) Coordination with certain tax treaties.

    85 FR 64346Treasury DepartmentInternal Revenue Service
  • Management of Federal Agency Disbursements

    Federal Register · Rule · Dec 22, 2010

    . including the District of Columbia, Guam, Puerto Rico, and U.S. … ATM cash withdrawal outside of U.S. Surcharge by ATM owner may apply $3.00 plus 3% of amount withdrawn. Purchase at Merchant Locations outside of U.S. 3% of purchase amount.

    75 FR 80315Treasury DepartmentFiscal Service
  • Small Business Taxpayer Exceptions Under Sections 263A, 448, 460 and 471

    Federal Register · Rule · Jan 5, 2021

    Commissioner, 519 F.2d 1280 (10th Cir. 1975), cert. denied 423 U.S. 1087 (1976) (requiring the full inclusion of all overhead costs in the cost basis of self-constructed assets) with Fort Howard Paper … These estimates come from information collected on Form 1120, U.S. Corporation Income Tax Return, Form 1065, U.S. Return of Partnership Income and Form 1120-S, U.S.

    86 FR 254Treasury DepartmentInternal Revenue Service
  • Meals and Entertainment Expenses Under Section 274

    Federal Register · Rule · Oct 9, 2020

    Commissioner, 307 F.3d 423 (6th Cir. 2002). … Statement of Availability of IRS Documents 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

    85 FR 64026Treasury DepartmentInternal Revenue Service
  • Amendments to Customs Bond Cancellation Standards

    Federal Register · Uncategorized Document · Apr 14, 1994

    DEPARTMENT OF THE TREASURY Customs Service [T.D. 94-38] Amendments to Customs Bond Cancellation Standards AGENCY: U.S. Customs Service, Department of the Treasury. … FOR FURTHER INFORMATION CONTACT: Jeremy Baskin, Penalties Branch, U.S. Customs Service, Franklin Court, 1301 Constitution Avenue, NW., Washington, DC 20229, (202) 482-6950.

    Treasury DepartmentCustoms Service
  • Foreign Tax Credit Guidance Related to the Tax Cuts and Jobs Act, Overall Foreign Loss Recapture, and Foreign Tax Redeterminations

    Federal Register · Rule · Dec 17, 2019

    On audit of USP's return for the taxable year, the IRS adjusted, under section 482, USP's sales to related foreign subsidiaries by increasing the sales price by a total of $100,000x, thereby increasing … In determining the amount of gross income that is attributable to a foreign branch that must be adjusted by reason of this paragraph (f)(2)(vi)(D), the principles of sections 367(d) and 482 apply.

    84 FR 69022Treasury DepartmentInternal Revenue Service
  • Source Rules Involving U.S. Possessions and Other Conforming Changes

    Federal Register · Rule · Apr 9, 2008

    U.S. … In the event that Y and Z are controlled taxpayers within the meaning of § 1.482-1(i)(5), section 482 and the regulations under that section, including § 1.482-9T(i), would apply to evaluate the arm's

    73 FR 19350Treasury DepartmentInternal Revenue Service
  • Establishment of the Alta Mesa, Borden Ranch, Clements Hills, Cosumnes River, Jahant, Mokelumne River, and Sloughhouse Viticultural Areas

    Federal Register · Rule · Jul 17, 2006

    ATF-482, published in the Federal Register at 67 FR 56481 on September 4, 2002, for the Lodi area expansion in 2002.) … More recently, the Borden Ranch name appeared in a court case and related news media stories involving a developer who sued the U.S.

    71 FR 40404Treasury DepartmentAlcohol and Tobacco Tax and Trade Bureau
  • Electronic-Filing Requirements for Specified Returns and Other Documents

    Federal Register · Proposed Rule · Jul 23, 2021

    301.6011-2(b)(1) to add the Form 3921, Exercise of an Incentive Stock Option Under Section 422(b), and Form 3922, Transfer of Stock Acquired Through an Employee Stock Purchase Plan Under Section 423 … Employer X is required to file the following: One Form 1120, U.S.

    86 FR 39910Treasury DepartmentInternal Revenue Service

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