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TREAS/IRS | RIN: 1545-BG54 | Publication ID: Fall 2008 |
Title: Reduction of Separate Foreign Tax Credit Limitation Categories | |
Abstract: The American Jobs Creation Act of 2004 amended the foreign tax credit limitation rules under section 904(d) by reducing the number of separate limitation categories to two categories, effective for taxable years beginning after December 31, 2006. These regulations would provide guidance needed to comply with these changes, including transition rules. | |
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 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-114126-07 Drafting attorney: Jeffrey L. Parry (202) 622-3850 CC: INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-BG55 | |
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 |