Internal Revenue Service June 12, 2009 – Federal Register Recent Federal Regulation Documents
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Open Meeting of the Taxpayer Advocacy Panel Notice Improvement Issue Committee; Correction
This document contains corrections to a notice of an open meeting of the Taxpayer Advocacy Panel Notice Improvement Issue Committee, that was published in the Federal Register on Tuesday, June 2, 2009 (74 FR 26483). The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Guidance Under Section 7874 Regarding Surrogate Foreign Corporations
This document contains final and temporary regulations under section 7874 of the Internal Revenue Code (Code) concerning the determination of whether a foreign corporation shall be treated as a surrogate foreign corporation. The temporary regulations primarily affect domestic corporations or partnerships (and certain parties related thereto), and certain foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. The text of these temporary regulations serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject also published in this issue of the Federal Register.
Guidance Under Section 7874 Regarding Surrogate Foreign Corporations
In the Rules and Regulations section of this issue of the Federal Register, the IRS and the Treasury Department are issuing temporary regulations concerning the treatment of a foreign corporation as a surrogate foreign corporation under section 7874(a)(2)(B) of the Internal Revenue Code (Code). The temporary regulations primarily affect domestic corporations and partnerships (and certain parties related thereto), and certain foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. The text of the temporary regulations serves as the text of these proposed regulations.
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