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TREAS/IRS | RIN: 1545-BL02 | Publication ID: Fall 2014 |
Title: Definition of a Taxpayer | |
Abstract:
This proposed regulation will clarify existing rules regarding the allocation, in certain cases, of foreign income taxes that are imposed on certain hybrid entities. |
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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 26 USC 0901 26 USC 0338 26 USC 0336 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-123045-12 Drafting attorney: Suzanne M. Walsh (202) 622-3850 Reviewing attorneys: Jeffrey Cowan and Barbara Felker (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-BL03 | |
Agency Contact: Suzanne M. Walsh Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6936 Fax:202 317-4922 Email: suzanne.m.walsh@irscounsel.treas.gov |