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TREAS/IRS | RIN: 1545-AY13 | Publication ID: Fall 2002 |
Title: Guidance for Imposing Tax Liability on Foreign Persons | |
Abstract: This temporary regulation provides guidance under section 894(c) of the Internal Revenue Code, 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: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Completed Actions |
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: Karen Rennie Quarrie (202) 622-3880 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: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
Agency Contact: Karen Rennie Senior Technical Reviewer Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3880 |