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federal_register: 2014-00899

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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
2014-00899 Guidance for Determining Stock Ownership Rule This document contains temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register. This document also contains a final regulation that provides a cross-reference to the temporary regulations. 2014-01-17 2014 1 https://www.federalregister.gov/documents/2014/01/17/2014-00899/guidance-for-determining-stock-ownership https://www.govinfo.gov/content/pkg/FR-2014-01-17/pdf/2014-00899.pdf Treasury Department; Internal Revenue Service 497,254 This document contains temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These...  

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  • 2 rows from document_number in federal_register_agencies
  • 1 row from fr_document_number in fr_regs_crossref
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