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TREAS/IRS | RIN: 1545-BK10 | Publication ID: Spring 2020 |
Title: Modifications to Definition of United States Property Under Section 956 | |
Abstract:
This regulation will address modification to the definition of United States property to clarify that certain upfront cash payments made by a controlled foreign corporation to its U.S. shareholders that are cleared through a clearinghouse do not constitute "United States property" under section 956. |
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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 |
EO 13771 Designation: Other | |
CFR Citation: 26 CFR 1.0956-2(T) | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 0956(e) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-107548-11 Drafting attorney: Kristine A. Crabtree (202) 317-6934 Reviewer attorney: N/A Treasury attorney: James Wang (202) 622-2198 CC:INTL | |
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 | |
Related RINs: Related to 1545-BK11 | |
Agency Contact: Kristine A. Crabtree Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4710, Washington, DC 20224 Phone:202 317-6934 Fax:202 317-4982 Email: kristine.a.crabtree@irscounsel.treas.gov |