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TREAS/IRS | RIN: 1545-BL45 | Publication ID: Spring 2014 |
Title: Guidance Under Sections 864 and 865 With Respect to Gain From the Disposition of Partnership Interest | |
Abstract: These regulations will provide rules regarding whether non-U.S. persons' gains from the disposition of interests in a partnership are treated as effectively connected with the conduct of a trade or business within the United States. | |
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: 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-151845-12 Drafting Attorney: David A. Levine (202) 622-3860 Reviewing Attorney: Jason T. Smyczek (202) 622-3860 Treasury Attorney: Unassigned 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: David A. Levine Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6937 Fax:202 317-4922 Email: david.a.levine@irscounsel.treas.gov |