Date: 2022-01-25
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-101828-19 HTML, PDF)
Document Number: 2022-00066, RIN: 1545-BP79
Action: Final regulations.
Abstract: This document contains final regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. The final regulations affect United States persons that own stock of foreign corporations through domestic partnerships and domestic partnerships that are United States shareholders of foreign corporations.
| Notable phrases | Frequency |
|---|---|
| U.S. shareholder partners | 35 |
| United States shareholder | 32 |
| within the meaning of section 958(a) | 20 |
| treated as owning | 17 |
| treatment of domestic partnerships | 12 |
| total combined voting power or value | 7 |
| stock of a foreign corporation | 7 |
| distributive share of the partnership's | 6 |
| share of the partnership's section 951 | 6 |
| Reg. Cites | Frequency |
|---|---|
| 1.958-1(d) | 11 |
| 1.951A-1(e) | 7 |
| 1.958-1(d)(1) | 6 |
| 1.958-1(d)(4) | 5 |
| 1.951-1 | 3 |
| 1.964-1(c)(5)(i) | 3 |
| 1.958-1(d)(2) | 2 |
| 1.951A-1 | 2 |
| 1.956-1(a)(2)(i) | 2 |
| 1.956-1(g)(4) | 2 |
| 1.956-1 | 2 |
| 1.958-1 | 2 |
| 1.1502-51 | 2 |
| 1.951-1(h) | 2 |
| Sec. Cites | Frequency |
|---|---|
| 951 | 58 |
| 951A | 31 |
| 958(a) | 29 |
| 956(a) | 11 |
| 956 | 9 |
| 1248 | 7 |
| 958(b) | 7 |
| 951(b) | 6 |
| 481 | 4 |
| 951(a) | 4 |
| 956(c) | 4 |
| 957(a) | 3 |
| 958 | 3 |
| 961 | 2 |
| 959 | 2 |
| 7805(f) | 2 |
| 7701(a)(4) | 2 |
| 1248(b)(1)(A) | 2 |
Statistics
Number of pages: 9, words: 8,830, sentences: 282
Average words per sentence: 31