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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
E8-14171 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 (within the meaning of section 956(c) of the Code) acquired by a controlled foreign corporation in certain nonrecognition transactions that are intended to repatriate earnings and profits of the controlled foreign corporation without United States income taxation. The final regulation adds a cross reference to the temporary regulations. These regulations affect United States shareholders of a controlled foreign corporation that acquires United States property in certain nonrecognition transactions. The text of the temporary regulations serves as the text of the proposed regulations (REG-102122-08) set forth in the notice of proposed rulemaking published in the Proposed Rules section in this issue of the Federal Register. 2008-06-24 2008 6 https://www.federalregister.gov/documents/2008/06/24/E8-14171/guidance-under-section-956-for-determining-the-basis-of-property-acquired-in-certain-nonrecognition https://www.govinfo.gov/content/pkg/FR-2008-06-24/pdf/E8-14171.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 (within the meaning of section 956(c) of the Code) acquired by a... 1545-BH58

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