{"abstract":"This document contains final regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25 percent foreign-owned domestic corporations under section 6038A of the Internal Revenue Code.","action":"Final regulations.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2016/12/13/2016-29641.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26},{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"81 FR 89849","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Effective date: These regulations are effective December 13, 2016.","disposition_notes":null,"docket_ids":["TD 9796"],"dockets":[],"document_number":"2016-29641","effective_on":"2016-12-13","end_page":89852,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2016/12/13/2016-29641.xml","html_url":"https://www.federalregister.gov/documents/2016/12/13/2016-29641/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2016-29641?publication_date=2016-12-13","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2016-12-13/2016-29641/mods.xml","not_received_for_publication":null,"page_length":4,"page_views":{"count":3526,"last_updated":"2026-08-26 18:15:08 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2016-12-13/pdf/2016-29641.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2016-29641.pdf?1481550327","publication_date":"2016-12-13","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2016/12/13/2016-29641.txt","regulation_id_number_info":{"1545-BM94":{"issue":"201610","html_url":"https://www.federalregister.gov/regulations/1545-BM94/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038(A)","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201610&RIN=1545-BM94&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BM94"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BM94/treatment-of-certain-domestic-entities-disregarded-as-separate-from-their-owners-as-corporations-for","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038(A)"},"comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2016-0019","supporting_documents_count":0,"docket_id":"IRS-2016-0019","regulation_id_number":"1545-BM94","title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A (REG-127199-15)","checked_regulationsdotgov_at":"2017-01-02T06:00:20Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":89849,"subtype":null,"title":"Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A","toc_doc":"Treatment of Certain Domestic Entities Disregarded as Separate from Their Owners as Corporations for Purposes of Section 6038A","toc_subject":null,"topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Rule","volume":81}