Internal Revenue Service December 11, 2020 – Federal Register Recent Federal Regulation Documents

Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax; Correction
Document Number: 2020-25374
Type: Rule
Date: 2020-12-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to Treasury Decision 9902, which was published in the Federal Register on Thursday, July 23, 2020. Treasury Decision 9902 contained 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.
Guidance Under Sections 951A and 954 Regarding Income Subject to a High Rate of Foreign Tax; Correcting Amendment
Document Number: 2020-25371
Type: Rule
Date: 2020-12-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to Treasury Decision 9902, which was published in the Federal Register on Thursday, July 23, 2020. Treasury Decision 9902 contained 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.
Source of Income From Certain Sales of Personal Property
Document Number: 2020-21817
Type: Rule
Date: 2020-12-11
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations modifying the rules for determining the source of income from sales of inventory produced within the United States and sold without the United States or vice versa. These final regulations also contain new rules for determining the source of income from sales of personal property (including inventory) by nonresidents that are attributable to an office or other fixed place of business that the nonresident maintains in the United States. Finally, these final regulations modify certain rules for determining whether foreign source income is effectively connected with the conduct of a trade or business within the United States.
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