Internal Revenue Bulletin: 2009-20
May 18, 2009
This document contains corrections to final and temporary regulations (T.D. 9441, 2009-7 I.R.B. 460) providing further guidance and clarification regarding methods under section 482 of the Code to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations.
This document contain corrections to proposed regulations (REG-143686-07, 2009-8 I.R.B. 579) providing guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies, as well as guidance regarding the determination of gain and the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions.
This document contains corrections to final regulations (T.D. 9394, 2008-21 I.R.B. 988) regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership’s obligation to pay withholding tax under section 1446 on effectively connected taxable income allocable under section 704 to such partner.
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