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TREAS/IRS | RIN: 1545-BE93 | Publication ID: Spring 2006 |
Title: Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities | |
Abstract: This regulation will provide guidance under section 7874(c)(2). Section 7874(a)(2)(B) provides that a foreign corporation will be a surrogate foreign corporation, if among other requirements, 60 percent of the stock of the entity is owned by former shareholders or partners of the domestic entity by reason of their holding an interest in the domestic entity. Section 7874(c)(2) states that in determining ownership under section 7874(a)(2)(B)(ii) stock held by members of the expanded affiliated group is disregarded. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 26 USC 7874 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-143244-05 Drafting Attorney: Jefferson VanderWolk (202) 622-3810 Reviewing Attorney: Milton Cahn (202) 622-3810 CC: INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
Related RINs: Related to 1545-BE94 | |
Agency Contact: Jefferson VanderWolk Special Counsel Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3810 |