Internal Revenue Bulletin: 2011-20
May 16, 2011
Final regulations under section 1563 of the Code, that apply to a controlled group of corporations, clarify that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.
This notice extends to taxable years that begin before the date that final regulations under regulations section 1.67-4 are published in the Federal Register, the interim guidance provided in Notice 2010-32, 2010-16 I.R.B. 594, Notice 2008-166, 2008-52 I.R.B. 1372, and Notice 2008-32, 2008-11 I.R.B 593, on the treatment under section 67 of the Code of investment advisory costs and other costs subject to the 2-percent floor under section 67(a) that are integrated as part of one commission or fee paid to the trustee or executor and are incurred by a trust other than a grantor trust or an estate. Notice 2010-32 modified and superseded.
This announcement contains a rescheduled notice of public hearing on proposed regulations (REG-146097-09, 2011-8 I.R.B. 516) providing guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals. A public hearing is rescheduled for May 18, 2011.
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