other · IRS · Rule · Published 2005-10-03 · Effective 2005-10-03 · 70 FR 57509
Document
Document number
05-19622
Federal Register citation
70 FR 57509
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
2005-10-03
Effective date
2005-10-03
Treasury docket
TD 9226
Abstract
This document contains final regulations relating to the determination of income of foreign insurance companies that is effectively connected with the conduct of a trade or business within the United States. The regulations provide that the exception to the asset-use test for stock shall not apply in determining whether the income, gain, or loss from portfolio stock held by foreign insurance companies constitutes effectively connected income.