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Federal Register · Rule · Jan 31, 2014
Trading) (Feb. 2012); BoA. 423 See BoA; RBC; LSTA (Feb. 2012). … An obligation guaranteed by the U.S. or an agency of the U.S. is, in effect, an obligation of the U.S. or that agency.
79 FR 5536Treasury DepartmentComptroller of the CurrencyPrivacy Act of 1974, as Amended; System of Records
Federal Register · Notice · Apr 3, 2012
Authority for Maintenance of the System: 12 U.S.C. 1, 481, and 482; 5 U.S.C. 301. … for the purpose of full filling a contract, compiling, organizing, analyzing, programming, or otherwise refining records to accomplish an agency function subject to the same limitations applicable to U.S
77 FR 20104Treasury DepartmentComptroller of the CurrencyFederal Register · Proposed Rule · Mar 27, 2026
See, e.g., U.S. … For debt positions in U.S.
91 FR 14952Treasury DepartmentComptroller of the CurrencyRules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments
Federal Register · Proposed Rule · Aug 7, 2024
Adjustments To Conform to U.S. … owner's regarded income can be reallocated to the books and records of the hybrid entity (and, thus, taken into account by the hybrid entity separate unit) under, for example, the principles of section 482
89 FR 64750Treasury DepartmentInternal Revenue ServiceRevision of Section 338 Consistency Rules.
Federal Register · Uncategorized Document · Jan 20, 1994
Waterman Steamship Corp., 430 F.2d 1185 (5th Cir. 1970), cert. denied, 401 U.S. 939 (1971). … ), qualified pension, profit-sharing, stock bonus and annuity plans (sections 401(a) and 403(a)), simplified employee pensions (section 408(k)), and tax qualified stock option plans (sections 422 and 423
Treasury DepartmentFederal Register · Rule · Mar 3, 2003
(Comment 423). … In re R.M.J., 455 U.S. 191, 203 (1982).
68 FR 10076Treasury DepartmentAlcohol and Tobacco Tax and Trade BureauFederal Register · Proposed Rule · Aug 15, 2005
ATF-482, published in the Federal Register on September 4, 2002 (67 FR 56481), 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.
70 FR 47740Treasury DepartmentAlcohol and Tobacco Tax and Trade BureauFederal Register · Rule · Feb 1, 2024
Air Force, U.S. Army, U.S. Coast Guard, U.S. Marine Corps, and U.S. … Armed Forces (including the U.S. Air Force, U.S. Army, U.S. Coast Guard, U.S. Marine Corps, U.S. Navy, and U.S. Space Force) or their dependents.
89 FR 6574Treasury DepartmentComptroller of the CurrencyGuidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income
Federal Register · Rule · Jan 4, 2022
including, but not limited to, a rebate, a refund, a credit, a deduction, a payment, a discharge of an obligation, or any other method) to the taxpayer, to a related person (within the meaning of section 482 … Subsequently, the Internal Revenue Service reallocates $200,000 of this income from B to A under the authority of section 482 and the tax treaty.
87 FR 276Treasury DepartmentInternal Revenue ServiceQualified Transportation Fringe, Transportation and Commuting Expenses under Section 274
Federal Register · Proposed Rule · Jun 23, 2020
Commissioner, 307 F.3d 423 (6th Cir. 2002). … Revenue Procedures, Revenue Rulings, and 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 37599Treasury DepartmentInternal Revenue ServiceFederal Register · Rule · Sep 4, 2024
Table B.2 reports the financial characteristics of small RIAs compared with all other RIAs impacted under the final rule based on information reported in their Form ADV filings. 423 Since information … small ERAs is not directly available, estimates of average AUM and number of legal entity clients for RIAs are also applied to ERAs to develop representative cost estimates for small advisers. 423
89 FR 72156Treasury DepartmentFinancial Crimes Enforcement NetworkAdvanced Manufacturing Production Credit
Federal Register · Rule · Oct 28, 2024
has been made, the election would not cause the sale price of such vessel to be treated as having been determined with respect to a transaction between uncontrolled taxpayers for purposes of section 482 … For related offshore wind vessel, such documentation could include the contract to construct or retrofit (along with retrofit plans), sales contract, U.S. Coast Guard bill of sale, U.S.
89 FR 85798Treasury DepartmentInternal Revenue ServiceFederal Register · Rule · Nov 15, 1995
Pena, 63 U.S.L.W. 4523 (U.S. June 12, 1995). … Ragen, 340 U.S. 462 (1951).
60 FR 57315Treasury DepartmentComptroller of the CurrencyGuidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income
Federal Register · Proposed Rule · Nov 12, 2020
Thus, for example, foreign tax laws that contain transfer pricing rules that are consistent with the arm's length standard under the section 482 regulations, or with the arm's length principle under the … activity by one member of a group of controlled taxpayers (the renderer) that results in a benefit to a controlled taxpayer (the recipient), and the renderer charges the recipient for such services, section 482
85 FR 72078Treasury DepartmentInternal Revenue ServicePurchase Price Allocations in Deemed and Actual Asset Acquisitions
Federal Register · Rule · Jan 7, 2000
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).
65 FR 1236RuleTreasury DepartmentBasis Reporting by Securities Brokers and Basis Determination for Stock
Federal Register · Proposed Rule · Dec 17, 2009
. payors and U.S. middlemen. … The Treasury Department and IRS request comments regarding the usefulness of information received from non-U.S. payors and non-U.S. middlemen, the costs to non-U.S. payors and non-U.S. middlemen of complying
74 FR 67010Treasury DepartmentInternal Revenue ServiceEconomic Growth and Regulatory Paperwork Reduction Act of 1996 Amendments
Federal Register · Rule · Jan 23, 2017
The OCC receives a number of applications and notices for changes to permanent capital that arise solely from applying U.S. generally accepted accounting principles (GAAP). For example, U.S. … These disclosures are in addition to those required under U.S. GAAP.
82 FR 8082Treasury DepartmentComptroller of the CurrencyGuidance Regarding Deduction and Capitalization of Expenditures
Federal Register · Proposed Rule · Dec 19, 2002
Winmill, 305 U.S. 79 (1938); § 1.263(a)-2(e). … Commissioner , 397 U.S. 572 (1970).
67 FR 77701Treasury DepartmentInternal Revenue ServiceOCC Rules Regarding the Availability of OCC Information
Federal Register · Proposed Rule · Aug 5, 2026
In addition, the U.S. … (v) U.S.-based consultants and U.S.
91 FR 50610Treasury DepartmentComptroller of the CurrencyGuidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions
Federal Register · Proposed Rule · Oct 23, 2002
Hernandez, 292 U.S. 62 (1934) (disallowing a worthless stock deduction recognized on a liquidation of a subsidiary member because the group had already obtained the tax benefit from the operating losses … stock or another asset is subject to redetermination, deferral, or disallowance under other applicable provisions of the Internal Revenue Code and regulations thereunder, including sections 267(f) and 482
67 FR 65060Treasury DepartmentInternal Revenue Service
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