Date | Agency Number | Description | Num. of Pages |
---|---|---|---|
2024-10-21 | TD 10008 | Withholding on Certain Distributions Under Section 3405(a) and (b) | 5 |
2024-10-10 | TD 9994 | Section 367(d) Rules for Certain Repatriations of Intangible Property | 11 |
2024-08-20 | REG-111629-23 | Guidance Regarding Elections Relating to Foreign Currency Gains and Losses | 6 |
2024-08-07 | REG-105128-23 | Rules Regarding DCLs and the Treatment of Certain Disregarded Payments | 29 |
2024-07-18 | TD 10004 | Guidance Under Section 367(b) Related to Certain Triangular Reorganizations and Inbound Nonrecognition Transactions | 12 |
2024-05-08 | REG-124850-08 | Transactions With Foreign Trusts and Information Reporting on Transactions With Foreign Trusts and Large Foreign Gifts | 46 |
2023-11-14 | REG-132422-17 | Income and Currency Gain or Loss With Respect to a QBU | 77 |
2023-06-07 | REG-106228-22 | Malta Personal Retirement Scheme Listed Transaction | 9 |
2023-04-11 | REG-109309-22 | Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest | 18 |
2023-02-23 | TD 9973 | Single-Entity Treatment of Consolidated Groups for Specific Purposes | 2 |
2022-12-29 | TD 9971 | Exception for Interests Held by Foreign Pension Funds | 26 |
2022-12-29 | REG-100442-22 | Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled QIEs | 12 |
2022-11-22 | REG-112096-22 | Guidance Related to the Foreign Tax Credit | 16 |
2022-09-30 | Fed. Reg. 2022-21020 | FinCEN beneficial ownership information reporting requirements | 99 |
2022-07-06 | REG-130675-17 | 1256 foreign currency contract definition | 5 |
2022-01-25 | REG-118250-20 | Partnerships & S corporations owning PFICs | 30 |
2022-01-25 | TD 9960 | 958 aggregate treatment for domestic partnerships for subpart F income | 9 |
2022-01-04 | TD 9959 | Foreign tax credits (discussion of foreign year end accrual in prop'd reg'ns) | 101 |
2021-09-24 | TD 9956 | Treatment of qualified improvement property under 250(b) and 951A(d) and guidance related to the FTC | 3 |
2021-01-15 | TD 9936 | PFIC indirect ownership, look-through rule, asset test, qualifying insurance corporation | 64 |
2020-12-11 | TD 9921 | Source of income from certain sales of personal property | 17 |
2020-11-30 | TD 9926 | 1446(f) withholding on dispositions of interests in partnerships engaged in a U.S. trade or business | 38 |
2020-11-12 | TD 9922 | Allocation of deductions and foreign taxes, redeterminations, hybrid deduction account, and more | 78 |
2020-11-06 | TD 9919 | 864(c)(6) gain or loss of foreign persons from sale or exchange of certain partnership interests | 15 |
2020-09-22 | TD 9908 | 958 downward attribution adjustments for 267, 332, 672(f), 706, 863, 904, 1297, 6049 | 9 |
2020-09-22 | REG-110059-20 | Ownership attribution under 958 for purposes of 367(a) and 954(c)(6) | 4 |
2020-09-14 | TD 9905 | 163(j) limitation on deduction for business interest expense (with special rules for CFCs) | 160 |
2020-08-27 | TD 9909 | Limitation on the DRD From Certain Foreign Corporations and Amounts Eligible for 954 Look-Through Exception | 30 |
2020-07-23 | TD 9902 | GILTI high tax exclusion (1.951A-2(c)(7)) | 30 |
2020-07-23 | REG-127732-19 | Guidance under 954(b)(4) regarding income subject to a high rate of foreign tax | 26 |
2020-07-15 | TD 9901 | 250 deduction for FDII and GILTI | 76 |
2020-04-08 | TD 9896 | 267A and 245A(e) rules regarding certain hybrid arrangements | 56 |
2020-01-23 | TD 9891 | Transfers of Certain Property by U.S. Persons to P'ships With Related Foreign Partners (721(c)) | 20 |
2019-12-17 | TD 9882 | Foreign tax credit guidance related to TCJA, overall foreign loss recapture, and foreign tax redeterminations | 102 |
2019-11-19 | TD 9883 | Ownership attribution - related to a CFC; rents derived in the active conduct of a trade or business | 3 |
2019-08-14 | REG-130700-14 | Cloud transactions and digital content | 13 |
2019-06-21 | TD 9866 | Guidance Related to Section 951A (GILTI) and Certain Guidance Related to Foreign Tax Credits | 83 |
2019-05-23 | TD 9859 | Amount determined under 956 for corporate United States shareholders | 4 |
2019-05-13 | TD 9857 | Recognition and Deferral of Section 987 Gain or Loss | 12 |
2018-07-12 | TD 9834 | Inversions and Related Transactions | 38 |
2016-12-28 | TD 9806 | Definitions and Reporting Requirements for Shareholders of PFICs | 12 |
2016-12-08 | TD 9794 | Income and Currency Gain or Loss With Respect to a Section 987 QBU | 47 |
2015-09-10 | REG-112997-10 | Guidance Under 2801 Regarding the Imposition of Tax on Certain Gifts and Bequests From Covered Expatriates | 22 |
2015-08-27 | REG-109813-11 | Residence Rules Involving U.S. Possessions | 3 |
* Proposed and temporary regulations are removed from this list after the related final regulations are added to the list.