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2019-12-17
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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
Proposed Rules
D09002ee1c1212cc3
D09002ee1c1212d6b
United States
Department of the Treasury
originator
org
United States Government Agency or Subagency
United States
Internal Revenue Service
originator
org
United States Government Agency or Subagency
This document contains proposed regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups.
84 FR 69124
https://www.govinfo.gov/app/details/FR-2019-12-17/2019-24847
2019-24847
fr17de19-26
RIN 1545-BP21
4830-01-P
REG-105495-19
https://www.govinfo.gov/app/details/FR-2019-12-17/2019-24847
https://www.govinfo.gov/content/pkg/FR-2019-12-17/html/2019-24847.htm
https://www.govinfo.gov/content/pkg/FR-2019-12-17/pdf/2019-24847.pdf
Income Taxes
Reporting and Recordkeeping Requirements
Employment Taxes
Estate Taxes
Excise Taxes
Gift Taxes
Penalties
57 p.
69124
69180
84 FR 69124
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Code of Federal Regulations
Title 26 Part 301
26 CFR Part 301
Regulation Identification Number 1545-BP21
RIN 1545-BP21
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 Vol. 84, Issue
PRORULE
2019-24847
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2020-02-18
REG-105495-19
4830-01-P
2019-24847
Notice of proposed rulemaking.
This document contains proposed regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups.
Written or electronic comments and requests for a public hearing must be received by February 18, 2020.
Concerning the proposed regulations under Sec. Sec. 1.861-8, 1.861-9(b), 1.861-12, 1.861-14, 1.861-17, and 1.954-2(h), Jeffrey P. Cowan, (202) 317-4924; concerning Sec. Sec. 1.704-1, 1.861-9(e), 1.904-4(e), 1.904(b)-3, 1.904(g)-3, 1.1502-4, and 1.1502-21, Jeffrey L. Parry, (202) 317-4916; concerning Sec. Sec. 1.861-20, 1.904-6, 1.960-1, and 1.960-7, Suzanne M. Walsh, (202) 317- 4908; concerning Sec. Sec. 1.904-4(c), 1.905-3, 1.905-4, 1.905-5, 1.954-1, 301.6227-1, and 301.6689-1, Larry R. Pounders, (202) 317-5465; concerning Sec. Sec. 1.965-5 and 1.965-9, Karen J. Cate, (202) 317- 4667; concerning submissions of comments and requests for a public hearing, Regina Johnson, (202) 317-6901 (not toll-free numbers).
Income Taxes
Reporting and Recordkeeping Requirements
Employment Taxes
Estate Taxes
Excise Taxes
Gift Taxes
Penalties
Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, the Definition of Financial Services Income, Foreign Tax Redeterminations Under Section 905(c), the Disallowance of Certain Foreign Tax Credits Under Section 965(g), and the Application of the Foreign Tax Credit Limitation to Consolidated Groups,
https://apps.irs.gov/app/picklist/list/draftTaxForms.htm
https://www.irs.gov/statistics
https://www.osha.gov/pls/imis/sic_manual.html
www.regulations.gov
Federal Register
Vol. 84, no. 242
Office of the Federal Register, National Archives and Records Administration
2019-12-17
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daily
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520 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2019-12-17
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https://www.govinfo.gov/app/details/FR-2019-12-17
https://www.govinfo.gov/content/pkg/FR-2019-12-17/pdf/FR-2019-12-17.pdf
https://www.govinfo.gov/content/pkg/FR-2019-12-17/xml/FR-2019-12-17.xml
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