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TREAS/IRS | RIN: 1545-BQ51 | Publication ID: Fall 2022 |
Title: ●Single-Entity Treatment of Consolidated Groups for Specific Purposes | |
Abstract:
Proposed rule to treat members of a consolidated group as a single United States shareholder for purposes of applying section 951(a)(2)(B) to distributions to which section 959(b) applies, and a proposed anti-avoidance rule. |
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Agency: Department of the Treasury(TREAS) | Priority: Other Significant |
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 1.1502-80 | |
Legal Authority: 26 U.S.C. 1502 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-113839-22 (NPRM) Drafter attorney: Joshua Roffenbender (202) 317-6934 Reviewer attorney: Paul McLaughlin (202) 317-5286 Treasury attorney: James Wang (202) 622-2198 INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
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 |