11 RULES: Section 482; Methods to Determine Taxable Income in Connection with a Cost
Correction
In rule document E830715 beginning on page 340 in the issue of Monday, January 5, 2009 make the following correction:
Sec. 1.4827T [Corrected]
On page 354, in Sec. 1.4827T(b)(5), in the second column, in paragraph (5), in the second line, ``(i) Situation in which Commissioner must treat arrangement as a CSA.'' should read
12 PROPOSED RULES: Clarification of Controlled Group Qualification Rules
This document contains a proposed regulation to clarify which corporations are included in a controlled group of corporations. The regulation clarifies that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.
13 RULES: Foreign Management and Foreign Economic Processes Requirements of a Foreign
[[Page 14479]]
CFR Correction
In Title 26 of the Code of Federal Regulations, Part 1 (Sec. Sec. 1.908 to 1.1000), revised as of April 1, 2008, in Sec. 1.924(c)1, make the following corrections:
1. On pages 62 and 63, remove paragraphs (d) introductory text, (d)(1) through (7), and (2) following (d)(7);
2. Reinstate paragraphs (d)(1)
14 RULES: Apportionment of Tax Items among the Members of a Controlled Group of
This document contains final regulations that provide guidance to corporations that are component members of a controlled group of corporations and to consolidated groups filing lifenonlife Federal income tax returns. They provide guidance to component members regarding the apportionment of tax benefit items and the amount and type of information
15 PROPOSED RULES: Allocation of Consideration and Allocation and Recovery of Basis in Transactions
This document contains proposed regulations under sections 301, 302, 304, 351, 354, 356, 358, 368, 861, 1001, and 1016 of the Internal Revenue Code (Code). The proposed regulations provide guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies,
16 PROPOSED RULES: Guidance Regarding Foreign Base Company Sales Income
This document contains corrections to a notice of proposed rulemaking and notice of public hearing that was published in the Federal Register on Monday, December 29, 2008 (73 FR 79421), relating to foreign base company sales income.
17 RULES: Section 482; Methods To Determine Taxable Income in Connection With a Cost
This document contains corrections to final and temporary regulations (TD9441) that were published in the Federal Register on Monday, January 5, 2009 (74 FR 340) providing further guidance and clarification regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement in order to address issues that
18 PROPOSED RULES: Liquidation of a Target, Followed by a Recontribution to a New Target, as a
This document contains corrections to a notice of proposed
rulemaking by crossreference to temporary regulations (REG13906808)
that were published in the Federal Register on Friday, September 4,
2009 (74 FR 45789) modifying the election under which a consolidated group can avoid immediately taking into account
[[Page 50759]]
an intercompany item
19 RULES: Income Taxes; Transfers of Property by U.S. Persons to Foreign Corporations; CFR
CFR Correction
In Title 26 of the Code of Federal Regulations, Part 1 (Sec. Sec. 1.301 to 1.400), revised as of April 1, 2008, on page 306, in Sec. 1.367(a)6T, in paragraph (e)(5)(ii)(B), reinstate the remainder of the first sentence, following the word ``some'', to read as follows: ``. . . portion of which was recaptured on the disposition,
20 RULES: Use of Controlled Corporations to Avoid the Application of Section (304)
This document contains final and temporary regulations under section 304 of the Internal Revenue Code (Code). The regulations apply to certain transactions that are subject to section 304 but that are entered into with a principal purpose of avoiding the application of section 304 to a corporation that is controlled by the issuing corporation in
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