Date: 2020-11-12
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-105600-18 HTML, PDF)
Document Number: 2020-21819, RIN: 1545-BP21
Action: Final and temporary regulations and removal of temporary regulations.
Abstract: This document contains final regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments, and the treatment of certain payments under the global intangible low-taxed income provisions.
Notable phrases | Frequency |
---|---|
foreign tax redetermination(s) | 194 |
gross intangible income | 103 |
foreign tax credit(s) | 92 |
allocat(ing|ion) and apportion(ing|ment) | 85 |
subpart F (income|inclusion) | 77 |
SIC code | 72 |
statutory and residual | 57 |
general category income | 55 |
item(s) of foreign gross income | 52 |
hybrid deduction account(s) | 50 |
stewardship expenses | 49 |
foreign branch category | 47 |
U.S. source income | 47 |
redetermination of U.S. tax | 46 |
controlled foreign corporation | 44 |
United States shareholder | 34 |
gross income method | 33 |
definitely related | 32 |
adjusted GILTI inclusion | 30 |
foreign branch category income | 29 |
class of gross income | 27 |
foreign tax credit limitation | 24 |
notify the IRS | 22 |
research and experimentation | 22 |
904 as the operative section | 19 |
foreign tax(es) deemed paid | 19 |
previously taxed earnings and profits | 18 |
foreign law inclusion regime | 17 |
related and allocable to | 13 |
foreign income tax(es) paid or accrued | 13 |
on the basis of the relative amounts | 12 |
asset method | 11 |
foreign gross income is assigned | 11 |
U.S. return of capital amount | 11 |
class of gross intangible income | 10 |
foreign personal holding company income | 9 |
members of the affiliated group | 9 |
apportioned to the statutory grouping | 8 |
apportioned to U.S. source income | 8 |
apportioned exclusively to the residual grouping | 7 |
foreign base company sales income | 7 |
apportioned among the statutory and residual groupings | 6 |
Reg. Cites | Frequency |
---|---|
1.861-17 | 27 |
1.905-4 | 25 |
1.861-20 | 21 |
1.861-9 | 15 |
1.861-14 | 14 |
1.904-6 | 13 |
1.904-4(f)(2)(vi) | 12 |
1.861-8 | 11 |
1.881-3 | 10 |
301.6689-1 | 10 |
1.905-5 | 10 |
1.6038-5 | 10 |
1.78-1(a) | 9 |
1.905-3(a) | 8 |
1.861-12 | 8 |
1.905-3(b)(2) | 8 |
1.6038-2(f)(14) | 8 |
1.1502-4 | 8 |
1.965-5(b)(2) | 7 |
1.905-5T | 7 |
Sec. Cites | Frequency |
---|---|
951A | 97 |
904 | 50 |
250 | 40 |
905(c) | 36 |
245A(e) | 34 |
78 | 30 |
954(b)(4) | 23 |
861 | 15 |
245A | 13 |
904(f) | 12 |
864(e)(3) | 12 |
965(a) | 10 |
901 | 10 |
243(a)(1) | 10 |
960(a) | 9 |
904(c) | 9 |
960 | 9 |
6511 | 9 |
951A(c)(2)(A)(i)(III) | 9 |
Statistics
Number of pages: 78, words: 87,677, sentences: 2,753
Average words per sentence: 31