The Department of the Treasury and the IRS anticipate issuing regulations under section 414(m) of the Internal Revenue Code to define the term affiliated service group. It is anticipated that an initial ANPRM will describe guidance under consideration and solicit comments on rules for determining whether two or more separate service entities constitute an affiliated service group under section 414(m). The ANPRM will also describe guidance under consideration and solicit comments on whether two unrelated organizations are in a management-type affiliated service group under section 414(m)(5).