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Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions

Document ID: IRS-2008-0058-0003
Document Type: Rule
Agency: Internal Revenue Service
Topics: Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number: E8-14171
CFR Citation: 26 CFR 1
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Details Information

Document Subtype:	Final Rule
Received Date:	June 24 2008, at 07:04 AM Eastern Daylight Time
Start-End Page:	35580 - 35583
Comment Start Date:	June 24 2008, at 12:00 AM Eastern Standard Time

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TIPRA Amendments to Section 199

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TIPRA Amendments to Section 199; Correction

Credit for Increasing Research Activities; Correction

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TIPRA Amendments to Section 199

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

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

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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

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Reporting of Gross Proceeds Payments to Attorneys

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

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Corporate Distributions and Adjustments

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

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

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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

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

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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

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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

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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

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

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

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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

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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

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Credit for Increasing Research Activities