Department of Treasury December 14, 2022 – Federal Register Recent Federal Regulation Documents

Single-Entity Treatment of Consolidated Groups for Specific Purposes
Document Number: 2022-27055
Type: Proposed Rule
Date: 2022-12-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that treat members of a consolidated group as a single United States shareholder in certain cases for purposes of section 951(a)(2)(B) of the Internal Revenue Code (the ``Code''). The proposed regulations affect consolidated groups that own stock of foreign corporations.
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