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- Documents
- Public Inspection
Publication date
Type
- Rule 25
- Proposed Rule 22
- Notice 7
Agency
- Treasury Department 28
- Internal Revenue Service 20
- Securities and Exchange Commission 7
- Agriculture Department 5
- Farm Service Agency 5
Topic
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Section
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Guidance on Passive Foreign Investment Companies
treatment of working capital for purposes of the Asset Test. Notice 88-22, 1988-1 C.B. 489 (“Notice 88-22”) provides that cash and other current assets readily … the section 958 proposed regulations were finalized at 85 FR 59428. A notice of proposed rulemaking...
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Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income
application of foreign law is not reasonable if there is actual notice or constructive notice (for example, a published court decision) to the taxpayer that … ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations relating to the...
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Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
Also on June 18, 2019, the Treasury Department and the IRS published a notice of proposed rulemaking (REG-106282-18) in the Federal Register (84 FR 28426 … proposed regulations (REG-103470-19), the text of which is set forth in a notice of proposed rulemaking published in the Proposed Rules...
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Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax
954(b)(4) in light of the changes made by the Act. As a result, a separate notice of proposed rulemaking published in the Proposed Rules section of this issue … I of this Summary of Comments and Explanation of Revisions, the separate notice of proposed rulemaking published concurrently with...
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Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income
as comments received in response to the solicitation of comments in the notice of proposed rulemaking. Comments outside the scope of this rulemaking are … contravenes the Congressional purpose behind FDII of encouraging the repatriation of intangible property. Another comment noted that if...
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Syria-Related Sanctions Regulations
constructive notice that such person's property and interests in property are blocked. (b) For the purposes of this section, constructive notice is the date … OFAC has the authority, pursuant to IEEPA, to issue Pre-Penalty Notices, Penalty
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Foreign Tax Credit Guidance Related to the Tax Cuts and Jobs Act, Overall Foreign Loss Recapture, and Foreign Tax Redeterminations
published a partial withdrawal of the notice of proposed rulemaking relating to the 1988 temporary regulations and a new notice of proposed rulemaking by cross-reference … those earnings were repatriated through a dividend distribution, section 956 served the...
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Guidance on Passive Foreign Investment Companies
ACTION: Withdrawal of notice of proposed rulemaking; notice of proposed rulemaking. SUMMARY: This document contains proposed regulations under … address the operation of the Income Test and Asset Test in Notice 88-22, 1988-1 C.B. 489 (“
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Guidance Under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income)
ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations regarding the treatment of domestic partnerships … rather which is the more appropriate and more consistent with Congressional intent with respect to the operation of the particular provision of the...
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Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits
following publications are obsolete as of June 21, 2019: Notice 2009-7 (2009-3 I.R.B. 312). Notice 2010-41 (2010-22 I.R.B. 715). Statement of Availability … as comments received in response to the solicitation of comments in the notices of proposed rulemaking...
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Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception
of foreign corporations end. Notice 2007-9, 2007-5 I.R.B. 401, provides guidance under section 954(c)(6). The notice describes additional guidance that … regulations also serves as the text of the proposed regulations set forth in a notice of proposed rulemaking...
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Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income
this notice of proposed rulemaking is not expected to be significant. The small business entities that are subject to section 250 and this notice of proposed … ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations that provide...
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Regulations Regarding the Transition Tax Under Section 965 and Related Provisions
Law 115-97 (2017) (the “Act”). See Notice 2018-07, 2018-4 I.R.B. 317; Notice 2018-13, 2018-6 I.R.B. 341; and Notice 2018-26, 2018-16 I.R.B. 480. Additional … discourage the repatriation of previously taxed E&P. In any event, the...
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Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Jobs Act
foreign tax credits) only upon repatriation allowed taxpayers to manage their foreign tax credit limitation by timing repatriations. However, the Act's reduction … ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations that...
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Democratic Republic of the Congo Sanctions Regulations
issue a Pre-Penalty Notice informing the alleged violator of the agency's intent to impose a monetary penalty. A Pre-Penalty Notice shall be in writing … constructive notice that such person's property and interests in property are...
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Disclosure Update and Simplification
operating in multiple jurisdictions 328 as well as the likelihood of repatriation of foreign earnings. 329 Some of the commenters who recommended the … the aggregate amount corporations would owe in U.S. taxes should they repatriate their offshore earnings. 330 In contrast, one commenter...
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Guidance Regarding the Transition Tax Under Section 965 and Related Provisions
965. See Notice 2018-07, 2018-4 I.R.B. 317; Notice 2018-13, 2018-6 I.R.B. 341; and Notice 2018-26, 2018-16 I.R.B. 480 (collectively, the “notices”); see … 965-1(e)(1). This is an expansion on the reference in section 2.13 of
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Investment Company Swing Pricing
e.g. over $100,000 or $250,000) or on such large redemptions if advance notice is not provided. 30 The details of the redemption fee and the circumstances … with portfolio asset purchases or sales (for example, transfer taxes and repatriation costs for certain foreign securities, or...
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Investment Company Liquidity Risk Management Programs
holdings of restricted securities may have to engage in private sales on short notice to meet redemption obligations, which could result in the fund “receiving … to tender their shares pursuant to a repurchase offer to provide advance notice thereof to such funds. 148 Commenters uniformly...
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Environmental Policies and Procedures; Compliance With the National Environmental Policy Act and Related Authorities
(ROD); (9) Notice of Intent (NOI) to prepare any type of EIS; (10) Notice of Availability (NOA) of environmental documents; (11) Notice of public scoping … NHPA National Historic Preservation Act. NOA Notice of...