Documents

Expanded Examination Cycle for Certain Small Insured Depository Institutions and U.S. Branches and Agencies of Foreign Banks

Federal Register · Rule · Feb 29, 2016

The interim final rules permit a U.S. branch or agency of a foreign bank with total assets of less than $1 billion to qualify for an 18-month examination cycle if the U.S. branch or agency of a foreign … The authority citation for part 4 is revised 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,

Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A

Federal Register · Rule · Nov 12, 2020

For purposes of the preceding sentence, a reasonable estimate based on the principles of section 482 must be made. See paragraph (g)(4)(ii)(B)( 3 ) of this section ( Example 4 ). … However, a reasonable estimate of Z's gross receipts attributable to the floodlights, based on the principles of section 482, is $120,000x.

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

Federal Register · Rule · Jul 31, 2020

Initial recordkeeping burdens: (10 hours) × (255 entities) × (Attorney at $423 per hour) = $1,078,650. 587  Annual recordkeeping burdens: (10 hours) × (255 entities) × (Attorney at $423 per hour … ) × (26 disclosures per year) × (Attorney at $423 per hour) = $1,402,245.

Guidance on Passive Foreign Investment Companies

Federal Register · Proposed Rule · Jul 11, 2019

Such strategies erode the U.S. tax base, and reflect inefficient investment incentives for U.S. taxpayers. … Individual Income Tax Return), (U.S. Income Tax Return for Estates and Trusts), 1065 (U.S. Return of Partnership Income), 1120 (U.S.

Amendments to Customs Bond Cancellation Standards

Federal Register · Uncategorized Document · Apr 11, 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, D.C. 20229, (202) 482-6950.

Express Consignments; Formal and Informal Entries of Merchandise; Administrative Exemptions

Federal Register · Rule · Apr 14, 1995

Rosoff, Office of Regulations and Rulings, (202-482-7040). … see, U.S.

Application of Modified Carryover Basis to General Basis Rules

Federal Register · Proposed Rule · May 11, 2015

share is subject to the adjustments provided by paragraphs (c)(4)(i)( b ) and ( c ) of this section, but such adjustments are only applicable in the case of an option that is subject to section 423 … For U.S. transferor decedents dying in 2010, the general rule of gain recognition under § 1.684-1 shall apply to any transfer of property by reason of death of the U.S. transferor if the basis of the property

Warehouse Withdrawals; Aircraft Fuel Supplies; Pipeline Transportation in Bond of Merchandise

Federal Register · Rule · Feb 22, 1996

Rosoff, Office of Regulations and Rulings, (202-482-7040). … the U.S. and any of its possessions, or between Hawaii and any other part of the U.S. or between Alaska and any other part of the U.S.

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.

Country of Origin Marking Requirements for Frozen Imported Produce

Federal Register · Proposed Rule · Jul 23, 1996

FOR FURTHER INFORMATION CONTACT: David Cohen, Special Classification and Marking Branch, Office of Regulations and Rulings (202-482-6980). … U.S. Customs Service, 15 CIT 60, 758 F.Supp. 729 (CIT 1991) (Norcal I).

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).

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.

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

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.

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,

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.

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'').

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.