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TREAS/IRS | RIN: 1545-BM90 | Publication ID: Fall 2016 |
Title: Ownership Attribution for Purposes of Determining Whether a Person is Related to a Controlled Foreign Corporation | |
Abstract:
These proposed regulations will address the application of certain constructive ownership rules in section 318 for purposes of defining the term "related person" in section 954(d)(3). |
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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: Undetermined | Unfunded Mandates: Undetermined |
CFR Citation: 26 CFR 0954-1 (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-125135-15 Drafting Attorney: Rose E. Jenkins (202) 317-6934 Reviewing Attorney: Barbara (202) 317-6934 Treasury Attorney: Brian Jenn CC:INTL | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: Undetermined |
Federalism: Undetermined | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Rose E. Jenkins Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6934 Fax:855 589-8671 Email: rose.e.jenkins@irscounsel.treas.gov |