Table of Contents

• T.D. 9476
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Background
    • Explanation of Provisions
    • 1. Only the Positive Taxable Income or Positive Alternative Minimum Taxable Income of the Component Members of a Controlled Group of Corporations Shall Be Combined for Purposes of Determining the Amount of the Additional Tax Imposed by Section 11(b)(1) and the Reduction in the Alternative Minimum Tax Exemption Amount Under Section 55(d)(3), Respectively.
    • 2. A Component Member That Has a Short Taxable Year That Does Not Include a December 31st Date Calculates Its Additional Tax and Alternative Minimum Tax Liability on Just Its Own Income.
    • 3. Clarification of the Rules under Which An Apportionment Plan Is Terminated.
    • Special Analyses
  • Adoption of Amendments to the Regulations
    • PART 1—INCOME TAXES
    • §1.924(a)-1T [Amended]
    • §1.1502-43T [Removed]
    • §1.1502-47T [Removed]
    • §1.1561-0T [Removed]
    • §1.1561-1T [Removed]
    • §1.1561-2T [Removed]
    • §1.1561-3T [Removed]
  • Drafting Information