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TREAS/IRS | RIN: 1545-BO93 | Publication ID: Fall 2018 |
Title: ●Electing Small Business Trusts With Nonresident Aliens as Potential Current Beneficiaries | |
Abstract:
Proposed regulations that provide guidance regarding the expansion of eligible potential current beneficiaries (PCBs) of an electing small business trust (ESBT) to include nonresident aliens (NRAs) by section 13541 of the Tax Cuts and Jobs Act, Pub. L. 115-97, 131 stat. 2054 (2017). These proposed regulations prevent NRAs who are PCBs from avoiding U.S. tax on certain types of S corporation income when these NRAs are owners of grantor trusts electing to be ESBTs. |
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Agency: Department of the Treasury(TREAS) | Priority: Other Significant |
RIN Status: First time published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: 26 CFR 1.641(c)-1 26 CFR 1.1361-1 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 1361(c)(2)(B)(v) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-117062-18 (NPRM) Drafter attorney: Cynthia Morton (202) 317-4630 Reviewer attorney: Richard Probst (202) 317-5044 Treasury attorney: Catherine Hughes (202) 622-9407 CC:PSI | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Cynthia D. Morton Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5011, Washington, DC 20224 Phone:202 317-4630 Fax:855 591-7865 Email: cynthia.d.morton@irscounsel.treas.gov |