Internal Revenue Service July 23, 2020 – Federal Register Recent Federal Regulation Documents
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Proposed Collection; Comment Request Concerning Time and Manner of Making Certain Elections Under the Technical and Miscellaneous Revenue Act of 1988, and the Redesignation of Certain Other Temporary Elections
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on continuing information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning time and manner of making certain elections under the technical and miscellaneous revenue act of 1988, and the redesignation of certain other temporary elections.
Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax
This document contains final regulations under the global intangible low-taxed income and subpart F income provisions of the Internal Revenue Code regarding the treatment of income that is subject to a high rate of foreign tax. The final regulations affect United States shareholders of foreign corporations. This guidance relates to changes made to the applicable law by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017.
Guidance Under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax
This document contains proposed regulations under the subpart F income and global intangible low-taxed income provisions of the Internal Revenue Code regarding the treatment of certain income that is subject to a high rate of foreign tax. This document also contains proposed regulations under the information reporting provisions for foreign corporations to facilitate the administration of certain rules in the proposed regulations. The proposed regulations would affect United States shareholders of controlled foreign corporations.
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