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» Consolidated Returns; Intercompany Obligations
Consolidated Returns; Intercompany Obligations
Document ID:
IRS-2008-0006-0003
Document Type:
Proposed Rule
Agency:
Internal Revenue Service
Topics:
Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number:
E7-19134
CFR Citation:
26 CFR 1
View Document:
Details Information
Document Subtype:
NPRM
Received Date:
September 28 2007, at 07:37 AM Eastern Daylight Time
Start-End Page:
55139 - 55152
Comment Start Date:
September 28 2007, at 12:00 AM Eastern Standard Time
Comment Due Date:
December 27 2007, at 11:59 PM Eastern Standard Time
Comments
View All
Total:
30
Comment on FR Doc # E7-19134
Submitter:
Hutchison, Roy
Posted:
01/25/2008
ID:
IRS-2008-0006-0004
Comment Period Closed
Dec 27,2007 11:59 PM ET
Comment on FR Doc # E7-19134
Submitter:
Kunkel, Paul
Posted:
01/25/2008
ID:
IRS-2008-0006-0005
Comment Period Closed
Dec 27,2007 11:59 PM ET
Comment on FR Doc # E7-19134
Submitter:
Olson, Brenda
Posted:
01/25/2008
ID:
IRS-2008-0006-0006
Comment Period Closed
Dec 27,2007 11:59 PM ET
Comment on FR Doc # E7-19134
Submitter:
Goff, Dick
Posted:
01/25/2008
ID:
IRS-2008-0006-0007
Comment Period Closed
Dec 27,2007 11:59 PM ET
Comment on FR Doc # E7-19134
Submitter:
Pappas, Basil
Posted:
01/25/2008
ID:
IRS-2008-0006-0008
Comment Period Closed
Dec 27,2007 11:59 PM ET
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Section 411(d)(6) Protected Benefits
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Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable
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REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions (Foreign Holders)
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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
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
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Section 1248 Attribution Principles
Computer Software Under Section 199(c)(5)(B)
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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
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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
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
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
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 on Passive Foreign Investment Company (PFIC) Purging Elections; Correction
Guidance Under Subpart F Relating to Partnerships
Guidance Under Subpart F Relating to Partnerships
Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction
Obligations of States and Political Subdivisions; Correction
Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities
Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities
Application of Normalization Accounting Rules to Balances of Excess Deferred Income Taxes and Accumulated Deferred Investment Tax Credits of Public Utilities Whose Assets Cease To Be Public Utility Property; Correction
[Federal Register: December 27, 2005 (Volume 70, Number 247)]
Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Section 1374 Effective Dates
Application of Normalization Accounting Rules to Balances of Excess Deferred Income Taxes and Accumulated Deferred Investment Tax Credits of Public Utilities Whose Assets Cease To Be Public Utility Property
Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction
Obligations of States and Political Subdivisions
Source of Income From Certain Space and Ocean Activities; Source of Communications Income; Hearing Cancellation
Guidance on Passive Foreign Investment Company (PFIC) Purging Elections
Information Reporting Relating to Taxable Stock Transactions
Updated Mortality Tables for Determining Current Liability
Partners Distributive Share
Guidance Under Section 951 for Determining Pro Rata Share; Correction
Guidance Under Section 951 for Determining Pro Rata Share; Correction
Low-Income Housing Credit Allocation and Certification; Revisions
Income Attributable to Domestic Production Activities
Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest
Source of Income From Certain Space and Ocean Activities; Source of Communications Income; Correction
Application of Section 409A to Nonqualified Deferred Compensation Plans
Stock Held by Foreign Insurance Companies
Partnership Equity for Services; Hearing Cancellation
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
Consolidated Returns; Intercompany Obligations
Details Information
Comments
View AllSubmitter: Hutchison, Roy Posted: 01/25/2008 ID: IRS-2008-0006-0004
Dec 27,2007 11:59 PM ET
Submitter: Kunkel, Paul Posted: 01/25/2008 ID: IRS-2008-0006-0005
Dec 27,2007 11:59 PM ET
Submitter: Olson, Brenda Posted: 01/25/2008 ID: IRS-2008-0006-0006
Dec 27,2007 11:59 PM ET
Submitter: Goff, Dick Posted: 01/25/2008 ID: IRS-2008-0006-0007
Dec 27,2007 11:59 PM ET
Submitter: Pappas, Basil Posted: 01/25/2008 ID: IRS-2008-0006-0008
Dec 27,2007 11:59 PM ET
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