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TREAS/IRS | RIN: 1545-BR24 | Publication ID: Fall 2024 |
Title: ●DISC Non-U.S. Shareholder Listed Transaction | |
Abstract:
The NPRM will treat as a listed transaction under section 6011, cases where a Non-U.S. DISC Shareholder: 1) Receives a distribution of accumulated Domestic International Sales Corporation (DISC) income, including a deemed distribution, or derives gain referred to in section 995(c) (relating to disposition of stock of a DISC); and 2) Claims, notwithstanding section 996(g), that an income tax treaty to which the United States is a party exempts or reduces tax on the income. |
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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 |
CFR Citation: 26 CFR 1.6011-19 | |
Legal Authority: 26 U.S.C. 6707A 26 U.S.C. 6111 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-118588-23 (NPRM) Drafter attorney: Allison Rasko (202) 317-6801 Drafter reviewer: Zeb Kelley (202) 317 -5447 Treasury attorney: James Wang (202) 622-2198 CC: INTL | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
International Impacts: This regulatory action will be likely to have international trade and investment effects, or otherwise be of international interest. | |
RIN Data Printed in the FR: No | |
Agency Contact: Allison L. Rasko Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Room 4579 , Washington, DC 20224 Phone:202 317-6801 Email: allison.l.rasko@irscounsel.treas.gov |