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These proposed regulations cross-reference final and temporary rules that improve the operation of an existing safe harbor rule that is used for determining whether partnership allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners’ interests in the partnership.
These temporary and final regulations provide rules that improve the operation of an existing safe harbor rule that is used for determining whether partnership allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners’ interests in the partnership.
This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effective January 1, 2016.
Serves notice to potential donors of a stipulated decision by the United States Tax Court in declaratory judgment proceedings under Section 7428.
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