Documents

Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups

Federal Register · Proposed Rule · Dec 17, 2019

Appropriate economic analyses, based on the principles of section 482, must be used to estimate gross receipts. See paragraph (g)(5)(B)( 3 )( ii ) of this section ( Example 5 ). … However, a reasonable estimate of Z's gross receipts attributable to the floodlights, based on the principles of section 482, is $120,000x.

Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

Federal Register · Rule · Jul 15, 2020

Intermediate Sales to a U.S. … made to the U.S. government.

Role of Supervisory Guidance

Federal Register · Proposed Rule · Nov 5, 2020

Mortgage Bankers Ass'n, 575 U.S. at 97 ( citing Shalala v. Guernsey Memorial Hospital, 514 U.S. 87, 99 (1995)). … Clearing House Assn L.L.C., 557 U.S. 519 (2009); United States v. Gaubert, 499 U.S. 315 (1991); and United States v. Philadelphia Nat. Bank, 374 U.S. 321 (1963).

General Revision of Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Related Collection, Refunds, and Credits; Revision of Information Reporting and Backup Withholding Regulations; and Removal of Regulations Under Part 35a and of Certain Regulations Under Income Tax Treaties

Federal Register · Rule · Oct 14, 1997

(2) Income allocated under section 482. A payment is considered made to the extent income subject to withholding is allocated under section 482. … Further, income arising as a result of a secondary adjustment made in conjunction with a reallocation of income under section 482 from a foreign person to a related U.S. person is considered paid to a

Inbound Grantor Trusts With Foreign Grantors

Federal Register · Rule · Aug 10, 1999

of U.S. tax. … In addition, commenters pointed out that there already are other provisions, such as sections 482 and 845, that apply to related-party reinsurance arrangements.

Subchapter K Anti-Abuse Rule

Federal Register · Rule · Jan 3, 1995

In determining whether a transaction clearly reflects the partners' income, the principles of sections 446(b) and 482 apply. … The CFC rules prevent the deferral by U.S. shareholders of U.S. taxation of certain earnings of the CFC and reduce disparities that otherwise might occur between the amount of income subject to a particular

Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements

Federal Register · Proposed Rule · Apr 10, 2026

, or U.S. … fewer, less complex SAR filings. 481 Table 8 presents this distribution, which results in a weighted annual average of 190 filings per PPSI, resulting in an annual burden of 285 hours per PPSI. 482

One-Year Post-Employment Restrictions for Senior Examiners

Federal Register · Rule · Nov 17, 2005

Subpart C also issued under 5 U.S.C. 301, 552; 12 U.S.C. 161, 481, 482, 484(a), 1442, 1817(a)(3), 1818(u) and (v), 1820(d)(6), 1820(k), 1821(c), 1821(o), 1821(t), 1831m, 1831p-1, 1831o, 1867, 1951 et … Any senior examiner who is subject to an order issued under paragraph (a)(1) of this section shall be subject to 12 U.S.

Rules of Origin for Textile and Apparel Products

Federal Register · Proposed Rule · May 23, 1995

FOR FURTHER INFORMATION CONTACT: Phil Robins, Office of Regulations and Rulings (202-482-7029). … U.S.

Investing in Qualified Opportunity Funds

Federal Register · Rule · Jan 13, 2020

Groetzinger, 480 U.S. 23, 25 (1987). … and all section 482 regulations in this chapter) at the time the lease is entered into

Pharmaceutical Tables 1 and 3 of the HTSUS

Federal Register · Notice · Apr 26, 1995

. ----------------------------------------------------------------------- SUMMARY: By act of Congress, the U.S. … U.S.

Proposed Agency Information Collection Activities; Comment Request

Federal Register · Notice · Jul 22, 2020

• For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … Revisions Related to U.S. GAAP 1.

Proposed Agency Information Collection Activities; Comment Request

Federal Register · Notice · Oct 4, 2019

• For assistance in navigating www.reginfo.gov, please contact the Regulatory Information Service Center at (202) 482-7340. … Under the proposed approach, the most stringent set of standards (Category I) would apply to U.S. global systemically important banks (GSIBs).

Privacy Act Regulations

Federal Register · Proposed Rule · Jul 25, 2022

SIGPR .423 Legal Records. (iv) Alcohol and Tobacco and Trade Bureau (TTB). … SIGPR .423 Legal Records. (iii) The Alcohol and Tobacco Tax and Trade Bureau (TTB).

Basis Reporting by Securities Brokers and Basis Determination for Stock

Federal Register · Rule · Oct 18, 2010

The final regulations do not adopt this comment because section 6045 does not distinguish between U.S. and non-U.S. issuers of securities. … (i) R, an employee of C, a corporation, participates in C's employee stock purchase program that satisfies the requirements of section 423. D administers the plan.

Privacy Act Regulations

Federal Register · Rule · Oct 20, 2022

SIGPR .423 Legal Records. (iv) Alcohol and Tobacco and Trade Bureau (TTB). Table 4 to Paragraph (c)(1)(iv) No. … SIGPR .423 Legal Records. (iii) The Alcohol and Tobacco Tax and Trade Bureau (TTB). Table 11 to Paragraph (g)(1)(iii) No.

Petroleum Refineries in Foreign Trade Subzones

Federal Register · Rule · Apr 27, 1995

FOR FURTHER INFORMATION CONTACT: For Legal aspects: Bill Rosoff, Chief, Entry Rulings Branch (202)482-7040. For Operational aspects: Louis Hryniw, Regulatory Audit (202)927-1100. … Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the U.S.

Prohibition on Use of Reputation Risk by Regulators

Federal Register · Proposed Rule · Oct 30, 2025

This practice can also result in distortions to industries and the U.S. economy, as the agencies' examiners use reputation risk to choose winners and losers among market participants and industries. … 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, 1831p

Meals and Entertainment Expenses Under Section 274

Federal Register · Proposed Rule · Feb 26, 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

Prohibition on the Use of Reputation Risk by Regulators

Federal Register · Rule · Apr 10, 2026

Significant adverse effects on competition, employment, investment, productivity, innovation or on the ability of U.S. … 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, 1831p