Table of Contents

• Notice 2005-10
  • SECTION 1. OVERVIEW
  • SECTION 2. BACKGROUND
  • SECTION 3. CASH DIVIDENDS
    • .01 In General
    • .02 Treatment of Distributions to Intermediary Pass-Through Entities
    • .03 Amount of Cash Dividend Not Reduced by Related Deductions or Expenses
    • .04 Interaction with Section 959
  • SECTION 4. DOMESTIC REINVESTMENT PLANS
    • .01 In General
    • .02 Procedural Requirements
    • .03 Specificity
    • .04 Amending the Domestic Reinvestment Plan
    • .05 Tracing or Segregating Funds
    • .06 Expenditures in Taxable Year of Election
    • .07 Partially Completed Domestic Reinvestment Plans
  • SECTION 5. EXPENDITURES THAT ARE INVESTMENTS IN THE UNITED STATES PURSUANT TO SECTION 965(b)(4)
    • .01 In General
    • .02 Funding of Worker Hiring, Training, and Other Compensation
    • .03 Infrastructure and Capital Investments
    • .04 Research and Development
    • .05 Financial Stabilization of the Corporation for the Purposes of Job Retention or Creation
    • .06 Acquisitions of Interests in Business Entities
    • .07 Advertising and Marketing Expenditures
    • .08 Intangible Property
  • SECTION 6. EXPENDITURES THAT ARE NOT INVESTMENTS IN THE UNITED STATES PURSUANT TO SECTION 965(b)(4)
    • .01 In General
    • .02 Executive Compensation
    • .03 Intercompany Distributions, Obligations, and Transactions
    • .04 Dividends and Other Distributions With Respect to Stock
    • .05 Stock Redemptions
    • .06 Portfolio Investments in Business Entities
    • .07 Debt Instruments or other Evidences of Indebtedness
    • .08 Tax Payments
  • SECTION 7. ELECTION TO APPLY SECTION 965 TO A TAXABLE YEAR
  • SECTION 8. REPORTING AND OTHER ADMINISTRATIVE REQUIREMENTS
    • .01 In General
    • .02 Reporting and Documentation Requirements
    • .03 Safe Harbor
    • .04 Facts and Circumstances
  • SECTION 9. TRANSITION RULES
    • .01 In General.
    • .02 Dividends Paid Prior to January 13, 2005.
    • .03 Tax Returns Filed Prior to January 13, 2005.
    • SECTION 10. EFFECTIVE DATE
  • SECTION 11. PAPERWORK REDUCTION ACT
  • SECTION 12. DRAFTING INFORMATION