Department of Treasury January 30, 2006 – Federal Register Recent Federal Regulation Documents
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Clarification of Definitions
This document contains final regulations defining the terms corporation and domestic in circumstances in which a business entity is created or organized in more than one jurisdiction. These regulations affect business entities that are created or organized under the laws of more than one jurisdiction.
Allocation and Apportionment of Expenses Alternative Method for Determining Tax Book Value of Assets
This document contains final regulations providing an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of Sec. 1.861-9T. The alternative tax book value method, which is elective, allows taxpayers to determine, for purposes of apportioning expenses, the tax book value of all tangible property that is subject to a depreciation deduction under section 168 by using the straight line method, conventions, and recovery periods of the alternative depreciation system under section 168(g)(2). The alternative tax book value method is intended to minimize basis disparities between foreign and domestic assets of taxpayers that may arise when taxpayers use adjusted tax basis to value assets under the tax book value method of expense apportionment. These final regulations may affect taxpayers that are required to apportion expenses under section 861.
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