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Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents

Document ID: IRS-2006-0311-0001
Document Type: Rule
Agency: Internal Revenue Service
Topics: Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number: E6-08699
CFR Citation: 26 CFR 1
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Received Date:	June 06 2006, at 07:06 AM Eastern Daylight Time
Start-End Page:	32437 - 32448
Comment Start Date:	June 6 2006, at 12:00 AM Eastern Standard Time

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Clarification of Section 6411 Regulations; Correcting Amendment

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Corporate Estimated Tax; Correction

Corporate Estimated Tax; Correcting Amendment

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Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated; Correction

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Disclosure Requirements With Respect to Prohibited Tax Shelter Transactions; Correction

Exclusions From Gross Income of Foreign Corporations; Correction

Employee Benefits--Cafeteria Plans

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Employee Benefits--Cafeteria Plans

Built-in Gains and Losses Under Section 382(h); Correction

Diversification Requirements for Variable Annuity, Endowment, and Life Insurance Contracts

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Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions

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Limitations on Benefits and Contributions Under Qualified Plans; Correction

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Section 1367 Regarding Open Account Debt; Correction

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Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments

Section 1367 Regarding Open Account Debt

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Computer Software Under Section 199(c)(5)(B)

Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction; Correction

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Depreciation of MACRS Property That Is Acquired in a Like-Kind Exchange or as a Result of an Involuntary Conversion

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

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Updated Mortality Tables for Determining Current Liability

Guidance Necessary To Facilitate Business Electronic Filing; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Guidance Necessary to Facilitate Business Electronic Filing Under Section 1561

Income taxes: Space and ocean activities and communications; source of income; correction

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction Notice

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Unified Rule for Loss on Subsidiary Stock

Qualified Amended Returns

Income Attributable to Domestic Production Activities; Correction

Reporting Rules for Widely Held Fixed Investment Trusts

Changes in Computing Depreciation

Exchanges of Property for an Annuity

Income and Currency Gain or Loss With Respect to a Section 987 QBU; Correction

Railroad Track Maintenance Credit; Hearing Cancellation

General Allocation and Accounting Regulations Under Section 141

Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; Stewardship Expense; Correction

Guidance Necessary To Facilitate Business Electronic Filing Under Section 1561

Treatment of Services Under Section 482 Allocation of Income and Deductions From Intangibles Stewardship Expense; Correction

Prohibited Allocations of Securities in an S Corporation

Residence Rules Involving U.S. Possessions; Correction

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Income taxes: Credit for increasing research activities

Income taxes: Income attributable to domestic production activities; deduction

Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals

Exclusion From Gross Income of Previously Taxed Earnings and Profits and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property; Correction

Exhanges of Property for an Annuity

Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

Partners Distributive Share: Foreign Tax Expenditures; Correction

TIPRA Amendments to Section 199; Correction

Credit for Increasing Research Activities; Correction

General Allocation and Accounting Regulations Under Section 141; Correction

Income and Currency Gain or Loss With Respect to a Section 987 QBU; Hearing Cancellation

Residence Rules Involving U.S. Possessions

Credit for Increasing Research Activities

Definition of Taxpayer for Purposes of Section 901 and Related Matters; Correction

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Hearing Cancellation

Limitations on Transfers of Built-in Losses

Attained Age of the Insured Under Section 7702; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Partners Distributive Share: Foreign Tax Expenditures

Exchanges of Property for an Annuity

Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

Determination of Interest Expense Deduction of Foreign Corporations; Correction

General Allocation and Accounting Regulations Under Section 141

Section 411(d)(6) Protected Benefits; Correction

Elimination of Country-by-Country Reporting to Shareholders of Foreign Taxes Paid by Regulated Investment Companies

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Correction

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Definition of Essential Governmental Function Under Section 7871 and Limitation to Activities Customarily Performed by States and Local Governments; Correction

Railroad Track Maintenance Credit

Income and Currency Gain or Loss With Respect to a Section 987 QBU

Special Depreciation Allowance

Dividends Paid Deduction for Stock Held in Employee Stock Ownership Plan

Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property

Computer Software Under Section 199(c)(5)(B); Hearing Cancellation

REMIC Residual Interests-Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders); Correction

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable

Income Attributable to Domestic Production Activities; Correction Notice

Effect of Election on Corporation

Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction

Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correcting Amendment

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Determination of Interest Expense Deduction of Foreign Corporations

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Correction Notice

Reporting of Gross Proceeds Payments to Attorneys; Correction

Section 1248 Attribution Principles; Correction

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments; Hearing

Section 411(d)(6) Protected Benefits

Income taxes: Stock transfer rules; carryover of tax attributes

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable

Definition of Taxpayer for Purposes of Section 901 and Related Matters

Reporting Rules for Widely Held Fixed Investment Trusts

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders)

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions (Foreign Holders)

Computer Software Under Section 199 (c)(5)(B); Hearing

Exclusion of Employees of 501(c)(3) Organizations in 401(k) and 401(m) Plans

Designated Roth Accounts Under Section 402A; Hearing

Reporting of Gross Proceeds Payments to Attorneys

United States Dollar Approximate Separate Transactions Method

Computer Software Under Section 199(c)(5)(B); Correction

Expenses for Household and Dependent Care Services Necessary for Gainful Employment; Correction

Corporate Distributions and Adjustments

Effect of Elections in Certain Multi-Step Transactions

Computer Software Under Section 199(c)(5)(B); Correction

Distributions of Interests in a Loss Corporation From Qualified Trusts

Information Returns Required With Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic Corporations

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction; Correction

Revisions to Regulations Relating To Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments

Designated Roth Accounts Under Section 402A; Hearing

Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correction

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents

Section 1248 Attribution Principles

Computer Software Under Section 199(c)(5)(B)

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction

Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction

Income taxes: Insurance companies; sale or acquisition of assets under section 338

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit; Correcting Amendment

Application of Section 338 to Insurance Companies; Correction

Withdrawal of Proposed Regulations Regarding Intercompany Transactions; Manufacturer Incentive Payments

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit; Correction

Intercompany Transactions; Manufacturer Incentive Payments

Revisions to Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Revisions of Information Reporting Regulations; Correction

Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations; Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations

Statutory Mergers and Consolidations

Guidance Under Section 1502; Amendment of Tacking Rule Requirements of Life-Nonlife Consolidated Regulations

Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities; Hearing Cancellation

Withdrawal of Proposed Regulations Relating to Redemptions Taxable as Dividends

Time for Filing Employment Tax Returns and Modifications to the Deposit Rules; Hearing Cancellation

Updated Mortality Tables for Determining Current Liability; Hearing Cancellation

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Time and Manner of Making Section 163(d)(4)(B) Election To Treat Qualified Dividend Income as Investment Income; Correction

Application of Section 338 to Insurance Companies

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit

Treatment of Excess Loss Accounts; Correction

Corporate Estimated Tax; Correction

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Time for Filing Employment Tax Returns and Modifications to the Deposit Rules; Correction

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Hearing Cancellation

Agent for a Consolidated Group With Foreign Common Parent

Income Taxes

Definition of Contribution in Aid of Construction Under Section 118(c)

[Federal Register: March 7, 2006 (Volume 71, Number 44)]

Corporate Estimated Tax

Special Rules Regarding Certain Section 951 Pro Rata Share Allocations

Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign Corporations

Partners Distributive Share; Hearing Cancellation

Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

Allocation and Apportionment of Expenses Alternative Method for Determining Tax Book Value of Assets

Designated Roth Accounts Under Section 402A

Statutory Mergers and Consolidations

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts

Treatment of Excess Loss Accounts

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction

Guidance Under Subpart F Relating to Partnerships

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[Federal Register: December 27, 2005 (Volume 70, Number 247)]

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Stock Held by Foreign Insurance Companies

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Section 411(d)(6) Protected Benefits; Correction

Source of Income From Certain Space and Ocean Activities; Source of Communications Income

Special Rule Regarding Certain Section 951 Pro Rata Share Allocations

Converting an IRA Annuity to a Roth IRA

Section 411(d)(6) Protected Benefits

Guidance Regarding the Simplified Service Cost Method and the Simplified Production Method

Return Required by Subchapter T Cooperatives Under Section 6012

Credit for Increasing Research Activities