21 PROPOSED RULES: Section 482; Methods to Determine Taxable Income in Connection With a Cost
This document contains corrections to a notice of proposed rulemaking by crossreference to temporary regulations (REG14461502) that was published in the Federal Register on Monday, January 5, 2009 providing further guidance and clarification regarding methods under section 482 to determine taxable income in connection with a cost sharing
22 RULES: Determination of Interest Expense Deduction of Foreign Corporations; Correction
This document contains corrections to final regulations (TD 9465) that were published in the Federal Register on Monday, September 28, 2009 (74 FR 49315) concerning the determination of the interest expense deduction of foreign corporations engaged in a trade or business within the United States. These final regulations conform the interest
23 PROPOSED RULES: Guidance Regarding Foreign Base Company Sales Income; Hearing Cancellation
This document cancels a public hearing on proposed rulemaking relating to the foreign base company sales income, in cases in which personal property sold by a controlled foreign corporation (CFC) is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the CFC. The temporary
24 RULES: Consolidated Returns; Intercompany Obligations; Correction,
This document contains corrections to final regulations (TD 9442) that were published in the Federal Register on Monday, December 29, 2008 (73 FR 79324) under section 1502 of the Internal Revenue Code providing guidance regarding the treatment of transactions involving obligations between members of a consolidated group.
25 RULES: Reasonable Good Faith Interpretation of Required Minimum Distribution Rules by
This document contains final regulations under sections 401(a)(9) and 403(b) of the Internal Revenue Code (Code) to permit a governmental plan to comply with the required minimum distribution rules by using a reasonable and good faith interpretation of the statute. These regulations affect administrators of, employers maintaining, participants in,
26 RULES: Gain Recognition Agreements with Respect to Certain Transfers of Stock or
This document contains a correction to final regulations (TD 9446) that were published in the Federal Register on Wednesday, February 11, 2009 (74 FR 6952) under section 367(a) of the Internal Revenue Code concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations.
27 RULES: Employee Stock Purchase Plans under Internal Revenue Code (Section 423)
This document contains the final regulations relating to options granted under an employee stock purchase plan as defined in section 423 of the Internal Revenue Code (Code). These final regulations affect certain taxpayers who participate in the transfer of stock pursuant to the exercise of options granted under an employee stock purchase plan.
28 PROPOSED RULES: Determination of Distributive Share When a Partner’s Interest Changes
This document contains proposed regulations regarding the determination of partners' distributive shares of partnership items of income, gain, loss, deduction and credit when a partner's interests varies during a partnership taxable year. Also, the proposed regulations modify the existing regulations regarding the required taxable year of a
29 PROPOSED RULES: Section 108(e)(8) Application to Partnerships; Hearing Cancellation,
This document cancels a public hearing on proposed rulemaking relating to the application of section 108(e)(8) of the Internal Revenue Code to partnerships and their partners.
30 RULES: Treatment of Services Under Section 482; Allocation of Income and Deductions
This document contains corrections to final regulations (TD 9456) that were published in the Federal Register on Tuesday, August 4, 2009 (74 FR 38830) providing guidance regarding the treatment of controlled services transactions under section 482 and the allocation of income from intangible property, in particular with respect to contributions by
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