Internal Revenue Service April 20, 2006 – Federal Register Recent Federal Regulation Documents

Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities; Hearing Cancellation
Document Number: E6-5923
Type: Proposed Rule
Date: 2006-04-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document cancels a public hearing on proposed regulations relating to the disregard of affiliate-owned stock in determining the percentage of stock of a foreign corporation held by former shareholders or partners of a domestic entity, in order to determine whether the foreign corporation is a surrogate foreign corporation under section 7874 of the Internal Revenue Code.
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