federal_register: E9-13769

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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
E9-13769 Guidance Under Section 7874 Regarding Surrogate Foreign Corporations Proposed Rule In the Rules and Regulations section of this issue of the Federal Register, the IRS and the Treasury Department are issuing temporary regulations concerning the treatment of a foreign corporation as a surrogate foreign corporation under section 7874(a)(2)(B) of the Internal Revenue Code (Code). The temporary regulations primarily affect domestic corporations and partnerships (and certain parties related thereto), and certain foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. The text of the temporary regulations serves as the text of these proposed regulations. 2009-06-12 2009 6 https://www.federalregister.gov/documents/2009/06/12/E9-13769/guidance-under-section-7874-regarding-surrogate-foreign-corporations https://www.govinfo.gov/content/pkg/FR-2009-06-12/pdf/E9-13769.pdf Treasury Department; Internal Revenue Service 497,254 In the Rules and Regulations section of this issue of the Federal Register, the IRS and the Treasury Department are issuing temporary regulations concerning the treatment of a foreign corporation as a surrogate foreign corporation under section... 1545-BF47

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