Internal Revenue Bulletin: 2009-27 |
July 6, 2009 |
Table of Contents
- Rev. Rul. 2009-18
- T.D. 9452
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation and Summary of Comments
- I. Interest Expense Apportionment
- A. Interest Expense of a 10/50 Corporation
- B. Definition of “10 Percent Owned Corporation”
- II. Carryover of unused foreign taxes under section 904(c)
- III. Look-through Rules as Applied to 10/50 Corporations
- A. General Application of Look-through
- B. Substantiation of Look-through Treatment
- C. Application of Section 904(h) to 10/50 Corporations
- D. Treatment of Earnings and Taxes Accumulated During a Non-look-through Period
- i. Reconstruction method
- ii. Safe harbor
- iii. Treatment of a Deficit Accumulated in a Non-look-through Period
- iv. Section 952(c) Recapture Accounts
- v. GOZA Election
- E. Pre-acquisition E&P
- IV. Recapture of an Overall Foreign Loss or Separate Limitation Loss Incurred in a Separate Category for Dividends from a 10/50 Corporation
- V. Regulations under Section 964
- A. Tax Elections, Adoptions of Method of Accounting or Taxable Year, and Changes in Method of Accounting or Taxable Year Made on Behalf of a CFC or 10/50 Corporation
- B. Section 481(a) Adjustments
- C. Miscellaneous cross-references
- Special Analyses
- Adoption of Amendments to the Regulations
- Drafting Information
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