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TREAS/IRS | RIN: 1545-AY13 | Publication ID: Fall 2000 |
Title: ●Guidance Under Section 894 (Temporary) | |
Abstract: The regulation provides guidance under section 894(c) for imposing tax liability on foreign persons receiving United States source income from entities treated as domestic corporations for United States tax purposes, and as fiscally transparent entities under the laws of the jurisdiction, whose treaty with the United States is being invoked. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: First time published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 26 USC 894 26 USC 871 26 USC 881 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-107101-00 Drafting attorney: Shawn Renee Pringle (202) 622-3850 Reviewing attorney: Elizabeth U. Karzon (202) 622-3880 Treasury attorney: Patrick Brown (202) 622-1754 CC:INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: Undetermined |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
Agency Contact: Shawn Renee Pringle Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3850 |