Documents

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

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  • 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.

    60 FR 40997Treasury DepartmentInternal Revenue Service
  • Allocation and Apportionment of Research and Experimental Expenditures

    Federal Register · Rule · Dec 22, 1995

    Proc. 92-56 (1992-2 C.B. 409), ``The Relationship Between U.S. … In 1996, X's gross income is $160,000, of which $140,000 is U.S. source income from domestic sales of gasoline engines and $10,000 is foreign source royalties from Y, and $10,000 is U.S. source interest

    60 FR 66502Treasury Department
  • Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

    Federal Register · Proposed Rule · Sep 11, 2026

    . shareholder's R&E expenditures) for which the U.S. shareholder is not required to be fully compensated under section 482 principles. … (c) Reallocation to U.S. source income.

    91 FR 57832Treasury DepartmentInternal Revenue Service
  • Inversions and Related Transactions

    Federal Register · Rule · Apr 8, 2016

    The 2014 notice defines a U.S. … a) U.S. shareholder

    81 FR 20858Treasury DepartmentInternal Revenue Service
  • Section 367(d) Rules for Certain Repatriations of Intangible Property

    Federal Register · Rule · Oct 10, 2024

    A “repatriation” denotes a subsequent transfer of intangible property to the U.S. transferor or a United States person (U.S. person) related to the U.S. transferor. … (4) Coordination with section 482. For further guidance, see § 1.367(d)-1T(g)(4) (5) Determination of fair market value. For further guidance, see § 1.367(d)-1T(g)(5).

    89 FR 82160Treasury DepartmentInternal Revenue Service
  • Retail Foreign Exchange Transactions

    Federal Register · Proposed Rule · Apr 22, 2011

    The major currencies currently are the U.S. … Additionally, you should send a copy of your comments to the OMB Desk Officer, by mail to U.S.

    76 FR 22633Treasury DepartmentComptroller of the Currency
  • Retail Foreign Exchange Transactions

    Federal Register · Rule · Jul 14, 2011

    The commenter responded that there is no U.S. policy interest in applying U.S. consumer protection rules to transactions with non-U.S. residents conducted by foreign branches. … The major currencies currently are the U.S.

    76 FR 41375Treasury DepartmentComptroller of the Currency
  • 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.

    85 FR 12120Treasury DepartmentComptroller of the Currency
  • 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.

    84 FR 18652Treasury DepartmentInternal Revenue Service
  • 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.

    84 FR 20790Treasury DepartmentInternal Revenue Service
  • 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.).

    60 FR 13352Treasury DepartmentCustoms Service
  • 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.

    85 FR 81270Treasury DepartmentComptroller of the Currency
  • 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).

    70 FR 57930Treasury DepartmentInternal Revenue Service
  • 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.

    89 FR 5297Treasury DepartmentComptroller of the Currency
  • 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.

    85 FR 86481Treasury DepartmentInternal Revenue Service
  • 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.

    88 FR 23370Treasury DepartmentInternal Revenue Service
  • 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.

    84 FR 16560Treasury DepartmentComptroller of the Currency
  • 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.

    67 FR 12863Treasury DepartmentInternal Revenue Service
  • 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.

    60 FR 50020Treasury Department
  • 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.

    Treasury Department

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