federal_register: 06-7195

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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
06-7195 Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property Proposed Rule This document contains proposed regulations that provide guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Internal Revenue Code (Code) and related basis adjustments under section 961 of the Code. These regulations reflect relevant statutory changes made in years subsequent to 1983. These regulations also address a number of issues that the current section 959 and section 961 regulations do not clearly answer. These regulations, in general, will affect United States shareholders of controlled foreign corporations and their successors in interest. 2006-08-29 2006 8 https://www.federalregister.gov/documents/2006/08/29/06-7195/exclusion-from-gross-income-of-previously-taxed-earnings-and-profits-and-adjustments-to-basis-of https://www.govinfo.gov/content/pkg/FR-2006-08-29/pdf/06-7195.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations that provide guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Internal Revenue Code (Code) and related basis adjustments under section 961... 1545-AY54

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