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TREAS/IRS | RIN: 1545-BG85 | Publication ID: Fall 2008 |
Title: Treatment of Certain Distributions From Qualified Investment Entities Under Internal Revenue Code Sections 892 and 897(H) | |
Abstract: This regulation contains proposed changes to existing final regulations regarding taxation of foreign governments and distributions from real estate investment trusts (REITs) and other qualified investment entities. The proposed changes are needed to clarify that distributions received by a foreign government from such qualified investment entities are not exempt from taxation under section 892 but are treated under section 897(h)(1) as gain recognized by a foreign government shareholder from the sale or exchange of a United States real property interest described in section 897(c)(1)(A)(l). | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: Undetermined | Unfunded Mandates: Undetermined |
CFR Citation: 26 CFR 1.892-3T 26 CFR 1.897-1 | |
Legal Authority: 26 USC 7805 26 USC 0892 26 USC 0897 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-130395-07 Drafting attorneys: David A. Juster (202) 622-3850 and Margaret A. Hogan (202) 622-3860 Reviewing attorneys: Richard L. Chewning (202) 622-3850 and Charles Besecky (202) 622-3860 Treasury attorney: Jesse Eggert (202) 622-3860 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-BG86 | |
Agency Contact: David A. Juster Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6936 Email: david.a.juster@irscounsel.treas.gov Margaret A. Hogan Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3860 Email: margaret.a.hogan@irscounsel.treas.gov |