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» Use of Controlled Corporations to Avoid the Application of Section 304
Use of Controlled Corporations to Avoid the Application of Section 304
Document ID:
IRS-2009-0039-0004
Document Type:
Rule
Agency:
Internal Revenue Service
Topics:
Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number:
2012-30967
CFR Citation:
26 CFR Part 1
View Document:
Details Information
Received Date:
December 26 2012, at 09:30 AM Eastern Standard Time
Start-End Page:
75844 - 75845
Comment Start Date:
December 26 2012, at 12:00 AM Eastern Standard Time
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0
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Section 482: Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; CFR Correction
Unified Rule for Loss on Subsidiary Stock; CFR Correction
Treatment of Overall Foreign and Domestic Losses; CFR Correction
Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Stewardship Expense; CFR Correction
Unified Rule for Loss on Subsidiary Stock; CFR Correction
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Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage; Correction
Indirect Stock Transfers and Coordination Rule Exceptions: Transfers of Stock or Securities in Outbound Asset Reorganizations
Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income
Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated; Correction
Noncompensatory Partnership Options
Treatment of Grantor of Option on Partnership Interest
Health Insurance Premium Tax Credit
Net Investment Income Tax; Correction
Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage
Failure To File Gain Recognition Agreements and Other Required Filings
Rules Relating to Additional Medicare Tax; Correction
Rules Relating to Additional Medicare Tax; Correction
Partners Distributive Share; Correction
Disclosure or Use of Information by Preparers of Returns; Correction
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Application of Section 172(h) Including Consolidated Groups
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Additional Requirements for Charitable Hospitals; Correction
Utility Allowances Submetering
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Health Insurance Premium Tax Credit; Correction
Basis of Indebtedness of S Corporations to Their Shareholders; Correction
Substantial Business Activities: Correction
Additional Requirements for Charitable Hospitals
Overall Foreign Loss Recapture on Property Dispositions
Treatment of Overall Foreign and Domestic Losses
Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor In Bankruptcy
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Property Transferred in Connection with Performance of Services under Section 83
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Regulations Revising Rules Regarding Agency for Consolidated Group
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Treatment of Gain Recognized with Respect to Stock in Certain Foreign Corporations Upon Distributions
Guidance under Sections 642 and 643 (Income Ordering Rules)
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Determination of Governmental Plan Status; Correction
Indian Tribal Government Plans; Correction
Reporting of Specified Foreign Financial Assets; Correction
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Reporting of Specified Foreign Financial Assets; Correction
Allocation and Apportionment of Interest Expense; Correction
Reporting of Specified Foreign Financial Assets; Correction
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Foreign Tax Credit Splitting Events
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Use of Differential Income Stream as Application of Income Method and as Consideration in Assessing Best Method
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Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options: Correction
New Markets Tax Credit Non-Real Estate Investments; Hearing Cancellation
Conduit Financing Arrangements
Determination of Governmental Plan Status; Correction
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Targeted Populations Under Section 45D(e)(2)
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Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options
Application of the Segregation Rules to Small Shareholders
Corporate Reorganizations; Allocation of Basis in All Cash D Reorganizations
Deduction for Qualified Film and Television Production Costs: Correction
Application of Section 108(e)(8) to Indebtedness Satisfied by a Partnership Interest
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Methods of Accounting Used by Corporations that Acquire Assets of Other Corporations: Correction
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Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations and Deferred Original Issue Discount Deductions
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Modification to Consolidated Return Regulation Permitting an Election: Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization
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Application of Section 367 to a Section 351 Exchange, etc.: Correction
Applications: Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1), etc.; Correction
Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction
Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities; Correction
Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
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Section 482; Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement; Correction
Further Guidance on the Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction
Notice to Participants of Consequences of Failing to Defer Receipt of Qualified Retirement Plan Distributions: Expansion of Applicable Election Period and Period for Notices; Hearing Cancellation
Section 108(e)(8) Application to Partnerships; Hearing Cancellation
Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1): Treatment of Gain Recognized under Section 301(c)(3) for Purposes of Section 1248
Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1)
Consolidated Returns; Intercompany Obligations; Correction
Consolidated Returns; Intercompany Obligations; Correction
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Guidance Regarding Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
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Section 707 Regarding Disguised Sales, Generally
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