federal_register: 2010-30895

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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
2010-30895 Source of Income From Qualified Fails Charges Rule This document contains temporary regulations which set forth the source of income attributable to qualified fails charges. The temporary regulations provide guidance about the treatment of fails charges for purposes of sections 871 and 881, which generally require gross-basis taxation of foreign persons not otherwise subject to U.S. net-basis taxation and the withholding of such tax under sections 1441 and 1442. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. 2010-12-08 2010 12 https://www.federalregister.gov/documents/2010/12/08/2010-30895/source-of-income-from-qualified-fails-charges https://www.govinfo.gov/content/pkg/FR-2010-12-08/pdf/2010-30895.pdf Treasury Department; Internal Revenue Service 497,254 This document contains temporary regulations which set forth the source of income attributable to qualified fails charges. The temporary regulations provide guidance about the treatment of fails charges for purposes of sections 871 and 881, which... 1545-BJ85

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