Internal Revenue Service June 6, 2006 – Federal Register Recent Federal Regulation Documents
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Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents
This document contains temporary regulations under section 7874 of the Internal Revenue Code (Code) relating to the determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of these temporary regulations also serves as the text of the proposed regulations (REG-112994-06) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register.
Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of those regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.
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