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26 CFR Part 1
[TD 8764]
RIN 1545-AV91
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments to the Income Tax
Regulations (26 CFR part 1) under sections 925 and 927 which were
Explanation of Provisions
These regulations set a deadline for an election to group
no later than the due date of the FSC’s timely filed U.S. income
earned by such person if the pricing rule under section 994 which
927(a)(2)(B).
regulation.
Special Analyses
It has been determined that this Treasury Decision is not a
on small business.
Drafting Information
List of Subjects
26 CFR Part l
read as follows:
FSCs.
* * * * *
8
(c) * * *
cannot be made later than the due date of the FSC’s timely filed
FSC’s first taxable year beginning after December 31, 1997. The
* * * * *
(e) * * *
* * * * *
9
* * * * *
(b) * * *
* * * * *
earned by such person if the pricing rule under section 994 which
rule.
section 925(a)(1);
transaction.
Michael P. Dolan
Deputy Commissioner of Internal Revenue
Donald C. Lubick
Acting Assistant Secretary of the Treasury