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TREAS/IRS | RIN: 1545-BH13 | Publication ID: Spring 2009 |
Title: Treatment of Overall Foreign and Domestic Losses | |
Abstract: Section 402 of the American Jobs Creation Act of 2004 enacted a new section 904(g) providing for the recharacterization of U.S. source income as foreign source income where a taxpayer's foreign tax credit limitation has been reduced as a result of an overall domestic loss. The regulation will provide rules for maintaining and recapturing overall domestic loss accounts relating to such recharacterization. The regulation will also include some revisions of the existing regulations regarding overall foreign loss recapture under section 904(f). | |
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: 25 CFR 1 | |
Legal Authority: 26 USC 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-141399-07 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 | |
Related RINs: Related to 1545-BH14 | |
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 |