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TREAS/IRS | RIN: 1545-BP96 | Publication ID: Fall 2020 |
Title: ●Election to Allocate and Apportion Interest Expense on Worldwide Basis | |
Abstract:
Regulations will provide guidance on the 864(f) election to allocate and apportion interest expense on a worldwide basis. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
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 864(f) (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 864(f)(5)(F) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-122798-20 (NPRM) Drafting attorney: Moshe Dlott (202) 317-4967 Reviewing attorney: Jeffrey Parry (202) 317-4916 Treasury attorney: Isaac Wood (202) 923-8177 CC:INTL | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Moshe Dlott Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-4967 Email: moshe.a.dlott@irscounsel.treas.gov |