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TREAS/IRS | RIN: 1545-BB28 | Publication ID: Fall 2008 |
Title: Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporation | |
Abstract: The American Jobs Creation Act of 2004 amended the foreign tax credit limitation rules under section 904(d) and extended lookthrough treatment to dividends paid by a 10/50 lookthrough corporation, generally effective retroactively for tax years beginning after December 31, 2002. These regulations would provide guidance needed to comply with these changes, including transition rules for dividends paid by a 10/50 lookthrough corporation. | |
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 904(d)(6) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-144784-02 Drafting attorney: Richard L. Chewning (202) 622-3850 Reviewing attorney: Barbara A. Felker (202) 622-3850 Treasury attorney: Ginny L. Chung (202) 622-9461 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 | |
Related RINs: Related to 1545-BF46 | |
Agency Contact: Richard L. Chewning Senior Counsel Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3850 Fax:202 622-4476 Email: richard.l.chewning@irscounsel.treas.gov |