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2019-10-02
article
Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder
Proposed Rules
D09002ee1c1214824
D09002ee1c12149b7
United States
Department of the Treasury
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org
United States Government Agency or Subagency
United States
Internal Revenue Service
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org
United States Government Agency or Subagency
This document contains proposed regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations affect United States persons that have ownership interests in or that make or receive payments to or from certain foreign corporations.
84 FR 52398
https://www.govinfo.gov/app/details/FR-2019-10-02/2019-20567
2019-20567
fr02oc19-15
RIN 1545-B052
4830-01-P
REG-104223-18
https://www.govinfo.gov/app/details/FR-2019-10-02/2019-20567
https://www.govinfo.gov/content/pkg/FR-2019-10-02/html/2019-20567.htm
https://www.govinfo.gov/content/pkg/FR-2019-10-02/pdf/2019-20567.pdf
Income Taxes
Reporting and Recordkeeping Requirements
13 p.
52398
52410
84 FR 52398
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Regulation Identification Number 1545-B052
RIN 1545-B052
Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder; Federal Register Vol. 84, Issue
PRORULE
2019-20567
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2019-12-02
REG-104223-18
4830-01-P
2019-20567
Notice of proposed rulemaking.
This document contains proposed regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations affect United States persons that have ownership interests in or that make or receive payments to or from certain foreign corporations.
Written or electronic comments and requests for a public hearing must be received by December 2, 2019.
Concerning the proposed regulations, Jorge M. Oben, (202) 317-6934; concerning submissions of comments and requests for a public hearing, Regina Johnson at (202) 317-6901 (not toll-free numbers).
Income Taxes
Reporting and Recordkeeping Requirements
Ownership Attribution Under Section 958 Including For Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder
,
http://www.irs.gov
www.regulations.gov
Federal Register
Vol. 84, no. 191
Office of the Federal Register, National Archives and Records Administration
2019-10-02
continuing
daily
deposited
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397 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2019-10-02
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0097-6326
0042-1219
0364-1406
769-004-00000-9
000582072
f:fr02oc19
https://www.govinfo.gov/app/details/FR-2019-10-02
https://www.govinfo.gov/content/pkg/FR-2019-10-02/pdf/FR-2019-10-02.pdf
https://www.govinfo.gov/content/pkg/FR-2019-10-02/xml/FR-2019-10-02.xml
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DGPO
2019-10-02
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FR-2019-10-02
machine generated
eng
FR
FR-2019-10-02
84
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