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TREAS/IRS | RIN: 1545-AX65 | Publication ID: Spring 2006 |
Title: Stock Transfer Rules--Carryover of Earnings and Taxes | |
Abstract: This regulation provides guidance with respect to how earnings and profits and foreign income tax accounts carry over under section 381 and are allocated under section 312 in certain transactions described in section 367(b) of the Internal Revenue Code. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously 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 367 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-116050-99 Drafting attorney: Jeffrey L. Parry (202) 622-3850 Reviewing attorney: Anne Devereaux (202) 622-3850 Treasury attorney: Andrew Froberg (202) 622-0851 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: Jeffrey L. Parry Senior Counsel Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4555, Washington, DC 20224 Phone:202 317-6936 Fax:202 317-4922 Email: jeffrey.l.parry@irscounsel.treas.gov |