41 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,
42 PROPOSED RULES: Guidance Regarding Treatment of Stock of a Controlled Corporation Under Section
This document contains a correction to a notice of proposed rulemaking by crossreference to temporary regulations (REG15067007) that was published in the Federal Register on Monday, December 15, 2008 (73 FR 75979) giving guidance regarding the distribution of stock of a controlled corporation acquired in a transaction described in section
43 PROPOSED RULES: Election of Reduced Research Credit under Section 280C(c)(3)
This document contains proposed regulations that amend the regulations concerning taxpayers who make the election to claim the reduced research credit. The proposed regulations simplify how taxpayers make the election and affect taxpayers that claim the research credit. This document also provides a notice of a public hearing on these proposed
44 PROPOSED RULES: Allocation of Consideration and Allocation and Recovery of Basis in Transactions
This document contains a correction to a notice of proposed rulemaking (REG14368607) that was published in the Federal Register on Wednesday, January 21, 2009 (74 FR 3509) providing guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies, as well
45 PROPOSED RULES: Election of Reduced Research Credit under Section 280C(c)(3); Hearing
This document cancels a public hearing on proposed rulemaking that amends the regulations concerning taxpayers who make the election to claim the reduced research credit. The proposed regulations simplify how taxpayers make the election and affect taxpayers that claim the research credit.
46 RULES: Special Rules To Reduce Section 1446 Withholding; Correction,
This document contains corrections to final regulations (TD 9394) that were published in the Federal Register on Tuesday, April 29, 2008 (73 FR 23069) regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership's obligation to pay withholding tax under section 1446 on
47 PROPOSED RULES: Section 707 Regarding Disguised Sales, Generally
This document withdraws proposed regulations relating to the treatment of transactions between a partnership and its partners as disguised sales of partnership interests between the partners under section 707(a)(2)(B) of the Internal Revenue Code. The withdrawal affects partnerships and their partners.
48 RULES: Requirement for Tax-Exempt Entities Not Currently Required to File
This document contains final regulations as required by section 6033(i)(1) describing the time and manner in which certain tax exempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual electronic notice including certain information required by section 6033(i)(1)(A)
49 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
50 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
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