federal_register: 2011-15741

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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
2011-15741 Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions Rule This document contains final and temporary regulations under section 956 of the Internal Revenue Code (Code) regarding the determination of basis in certain United States property acquired by a controlled foreign corporation in certain nonrecognition transactions that are intended to repatriate earnings and profits of the controlled foreign corporation without U.S. income taxation. The regulations affect United States shareholders of a controlled foreign corporation that acquires United States property in certain nonrecognition transactions. 2011-06-24 2011 6 https://www.federalregister.gov/documents/2011/06/24/2011-15741/guidance-under-section-956-for-determining-the-basis-of-property-acquired-in-certain-nonrecognition https://www.govinfo.gov/content/pkg/FR-2011-06-24/pdf/2011-15741.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final and temporary regulations under section 956 of the Internal Revenue Code (Code) regarding the determination of basis in certain United States property acquired by a controlled foreign corporation in certain nonrecognition... 1545-BH56

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