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TREAS/IRS | RIN: 1545-AY54 | Publication ID: Fall 2022 |
Title: Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property | |
Abstract:
The regulations will address exclusions from income of previously taxed earnings and profits under section 959, accounting for previously taxed earnings and profits, and basis adjustments under section 961 related to previously taxed earnings and profits. The regulations will generally include the rules described in Notice 2019-01. |
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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: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 U.S.C. 959 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-121509-00 Drafting attorney: Joshua P. Roffenbender (202) 317-6934 Reviewing attorney: Melinda E. Harvey (202) 317-6934 Treasury attorney: Brenda Zent (202) 622-6894 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 | |
Agency Contact: Joshua P. Roffenbender Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Room 4706, Washington, DC 20224 Phone:202 317-6934 Fax:855 584-5146 Email: joshua.p.roffenbender@irscounsel.treas.gov |