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TREAS/IRS | RIN: 1545-AM11 | Publication ID: Fall 2008 |
Title: Clarification of Treatment of Separate Limitation Losses | |
Abstract: Section 1203 of the Tax Reform Act of 1986 amends section 904(f) by adding paragraph (f)(5) at the end thereof, which requires that foreign source losses with respect to any income category first offset a taxpayer's other foreign source income before such losses offset the taxpayer's U.S. source income. The regulation will provide rules for the allocation of foreign source losses. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Long-Term Actions |
Major: No | Unfunded Mandates: Undetermined |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-209044-89 (INTL-338-89) Drafting attorney: Jeffrey L. Parry (202) 622-3850 Reviewing attorney: Barbara A. Felker (202) 622-3850 CC: INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Jeffrey L. Parry Senior Counsel Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4555, Washington, DC 20224 Phone:202 317-6936 Fax:202 317-4922 Email: jeffrey.l.parry@irscounsel.treas.gov |