federal_register: 05-16610

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
05-16610 Special Rule Regarding Certain Section 951 Pro Rata Share Allocations Proposed Rule This document contains proposed amendments to regulations under section 951(a) of the Internal Revenue Code (Code) regarding a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base country shipping operations. These proposed regulations are intended to ensure that a CFC's earnings and profits for a taxable year attributable to a section 304 transaction will not be allocated in a manner that results in the avoidance of Federal income tax. These proposed regulations are also intended to ensure that earnings and profits of a CFC are not allocated to certain preferred stock in a manner inconsistent with the economic interest that such stock represents. 2005-08-25 2005 8 https://www.federalregister.gov/documents/2005/08/25/05-16610/special-rule-regarding-certain-section-951-pro-rata-share-allocations https://www.govinfo.gov/content/pkg/FR-2005-08-25/pdf/05-16610.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed amendments to regulations under section 951(a) of the Internal Revenue Code (Code) regarding a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously... 1545-BE71

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