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TREAS/IRS | RIN: 1545-BP21 | Publication ID: Fall 2020 |
Title: Allocation & Apportionment of Deductions & Foreign Taxes, Foreign Tax Redeterminations, FTC Disallowance Under 965(g), Consolidated Groups, Hybrid Arrangements & Certain Payments under 951A | |
Abstract:
Proposed regulations relating to follow-on guidance for changes to the foreign tax credit after the Tax Cuts and Jobs Act. |
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Agency: Department of the Treasury(TREAS) | Priority: Economically Significant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: Yes | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: None (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-105495-19 (NPRM) Drafter attorney: Jeffery Cowan (202) 317-4924 Reviewer attorney: Barbara Felker (202) 317-4925 Treasury attorney: Jason Yen (202) 622-1776 CC:INTL:B03 | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: Federal |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Jeffrey P. Cowan Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6936 Fax:202 317-4922 Email: jeffrey.p.cowan@irscounsel.treas.gov |