Internal Revenue Bulletin:  2005-40 

October 3, 2005 

INCOME TAX


T.D. 9222 T.D. 9222

Final regulations under section 951 of the Code prescribe rules under which a United States shareholder of a controlled foreign corporation (CFC) determines its pro rata share of the subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations.

REG-144615-02 REG-144615-02

Proposed regulations under section 482 of the Code provide guidance with respect to the sharing of costs and risks under cost sharing arrangements. They replace the existing guidance under regulations section 1.482-7 to provide clarification and additional guidance regarding the scope and valuation of the external inputs for which arm’s length consideration must be provided as an entry condition into cost sharing (“buy-ins” under the current regulations), as well as to address other technical and procedural issues that have arisen in the course of the administration of the cost sharing rules. A public hearing is scheduled for November 16, 2005.

REG-129782-05 REG-129782-05

Proposed regulations under section 951 of the Code prescribe rules under which a United States shareholder of a controlled foreign corporation (CFC) determines its pro rata share of the subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations, when a CFC’s earnings and profits for a taxable year substantially exceed its net income under United States generally accepted accounting principles  (US GAAP).


More Internal Revenue Bulletins