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).

Special Inspector General for Pandemic Recovery Committee-Systems: SIGPR .420-Audit and Evaluations Records; SIGPR .421-Case Management System and Investigative Records; and SIGPR .423-Legal Records; Privacy Act of 1974; Proposed Implementation

Federal Register · Proposed Rule · Apr 15, 2021

FOR FURTHER INFORMATION CONTACT: For questions about this notice and privacy issues, contact: Deputy Assistant Secretary for Privacy, Transparency, and Records at U.S. … In as much as the Privacy Act rights are personal and apply only to U.S. citizens or an alien lawfully admitted for permanent residence, small entities, as defined in the RFA, are not provided rights under

Donations of Technology and Support Services To Enforce Intellectual Property Rights

Federal Register · Proposed Rule · Jan 17, 2017

DEPARTMENT OF HOMELAND SECURITY U.S. … Section 482(a)(3).

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.

Semiannual Agenda

Federal Register · Proposed Rule · Feb 9, 2024

RIN: 1506-AB36 423. … L. 114-125); 19 U.S.C. 1595a(c)(2)(G); 19 U.S.C. 1624 Abstract: This rule amends the U.S.

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.

Departmental Offices; Disclosure of Records: Freedom of Information Act

Federal Register · Proposed Rule · May 6, 1999

Service of process will be received by the United States Secret Service Chief Counsel at the following address: Chief Counsel, U.S. … The U.S. Mint will provide a room on an ad hoc basis when necessary.

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

Country of Origin Marking Requirements for Frozen Imported Produce

Federal Register · Proposed Rule · Aug 18, 1997

ADDRESSES: Written comments (preferably in triplicate) may be addressed to the Regulations Branch, Office of Regulations and Rulings, U.S. … FOR FURTHER INFORMATION CONTACT: David Cohen, Special Classification and Marking Branch, Office of Regulations and Rulings (202-482-6980).

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.

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 · Jun 5, 1995

AB19; 1515-AB34 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 AGENCY: U.S … FOR FURTHER INFORMATION CONTACT: Sandra Gethers, Office of Regulations and Rulings (202-482-6980).

Drawback

Federal Register · Proposed Rule · Mar 3, 1997

[[Page 9402]] ADDRESSES: Comments (preferably in triplicate) must be submitted to U.S. … FOR FURTHER INFORMATION CONTACT: Paul Hegland, Office of Regulations and Rulings, (202-482-7040).

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.

Review of Customs Regulations

Federal Register · Proposed Rule · Apr 13, 1995

DEPARTMENT OF THE TREASURY Customs Service 19 CFR Chapter I Review of Customs Regulations AGENCY: U.S. Customs Service, Department of the Treasury. … FOR FURTHER INFORMATION CONTACT: Harold Singer, Regulations Branch, 202-482-6930.

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).