Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF Download
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Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729689134 Category : Languages : en Pages : 70
Book Description
Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations that apply to transfers of certain property by a domestic corporation to a foreign corporation in certain nonrecognition exchanges, or to distributions of stock of certain foreign corporations by a domestic corporation in certain nonrecognition distributions. The final regulations also establish reporting requirements for property transfers and stock distributions to which the final regulations apply. The regulations affect domestic corporations that transfer property to foreign corporations in certain nonrecognition transactions, or that distribute the stock of certain foreign corporations in certain nonrecognition distributions, and certain domestic shareholders of those domestic corporations. This book contains: - The complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729689134 Category : Languages : en Pages : 70
Book Description
Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations that apply to transfers of certain property by a domestic corporation to a foreign corporation in certain nonrecognition exchanges, or to distributions of stock of certain foreign corporations by a domestic corporation in certain nonrecognition distributions. The final regulations also establish reporting requirements for property transfers and stock distributions to which the final regulations apply. The regulations affect domestic corporations that transfer property to foreign corporations in certain nonrecognition transactions, or that distribute the stock of certain foreign corporations in certain nonrecognition distributions, and certain domestic shareholders of those domestic corporations. This book contains: - The complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729710296 Category : Languages : en Pages : 28
Book Description
Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also finalize modifications to the exception to the coordination rule for section 351 exchanges so that it is consistent with the remaining asset reorganization exception. In addition, the regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements. Finally, the regulations finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. These regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. This book contains: - The complete text of the Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729710272 Category : Languages : en Pages : 34
Book Description
Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. The text of these temporary regulations serves as the text of the proposed regulations (REG-132702-10) published in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. This book contains: - The complete text of the Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729735466 Category : Languages : en Pages : 52
Book Description
Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The regulations also combine certain sections of the existing regulations under section 367(a) into a single section. This document also withdraws certain temporary regulations. This book contains: - The complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729689165 Category : Languages : en Pages : 54
Book Description
Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. The final regulations are necessary to update cross-references in the current regulations. The temporary regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of these temporary regulations also serves as the text of the proposed regulations (REG-147144-06) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register. This book contains: - The complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729735749 Category : Languages : en Pages : 40
Book Description
United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income (FPHCI), as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions. This document finalizes proposed regulations, and withdraws temporary regulations, published on September 2, 2015. It also finalizes proposed regulations, and withdraws temporary regulations, published on June 14, 1988. The final regulations affect United States shareholders of CFCs. This book contains: - The complete text of the United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729701263 Category : Languages : en Pages : 62
Book Description
Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 367(a) of the Internal Revenue Code (Code) concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations. The regulations finalize temporary regulations published on February 5, 2007 (TD 9311). The regulations primarily affect United States persons that transfer (or have transferred) stock or securities to foreign corporations and that will enter (or have entered) into a gain recognition agreement with respect to such a transfer. This book contains: - The complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729734568 Category : Languages : en Pages : 34
Book Description
Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations regarding whether a foreign corporation is treated as a surrogate foreign corporation. The final regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. This book contains: - The complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729704783 Category : Languages : en Pages : 34
Book Description
Guidance Under Section 7874 Regarding Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Guidance Under Section 7874 Regarding Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 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. This book contains: - The complete text of the Guidance Under Section 7874 Regarding Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section