Internal Revenue Bulletin:  2009-9 

March 2, 2009 

INCOME TAX


T.D. 9444 T.D. 9444

Final, temporary, and proposed regulations under section 367 of the Code provide rules for the treatment of certain shareholders who transfer stock or securities of controlled corporations to foreign corporations. The regulations also address certain distributions shareholders receive with respect to the stock of controlled foreign corporations.

REG-147636-08 REG-147636-08

Final, temporary, and proposed regulations under section 367 of the Code provide rules for the treatment of certain shareholders who transfer stock or securities of controlled corporations to foreign corporations. The regulations also address certain distributions shareholders receive with respect to the stock of controlled foreign corporations.

T.D. 9445 T.D. 9445

Final regulations under section 6103 of the Code relate to administrative review procedures for certain government agencies and other authorized recipients of returns or return information whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards.

T.D. 9446 T.D. 9446

Final regulations under section 367 of the Code provide rules for entering into gain recognition agreements under section 367(a). The regulations clarify the effect that various transactions have on existing gain recognition agreements. Notice 2005-74 obsoleted.


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