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Residence and Source Rules Involving U.S. Possessions and Other Conforming Changes

tax-irs · IRS · Rule · Published 2005-04-11 · Effective 2005-04-11 · 70 FR 18920

Document

Document number
05-7087
Federal Register citation
70 FR 18920
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2005-04-11
Effective date
2005-04-11
Treasury docket
TD 9194

Abstract

This document contains temporary regulations that provide rules under section 937(a) of the Internal Revenue Code (Code) for determining whether an individual is a bona fide resident of the following U.S. possessions: American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the United States Virgin Islands. The temporary regulations also provide rules under section 937(b) for determining whether income is derived from sources within a U.S. possession and whether income is effectively connected with the conduct of a trade or business within a U.S. possession. Section 937 was added to the Code by section 908 of the American Jobs Creation Act (2004 Act). The temporary regulations also provide updated guidance under sections 876, 881, 884, 931, 932, 933, 934, 935, 957, and 6688 of the Code to reflect amendments made by the Tax Reform Act of 1986 (1986 Act) and the 2004 Act. Conforming changes are also made to regulations under sections 170A, 243, 702, 861, 863, 871, 901, 1402, 6038, 6046, and 7701 of the Code. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the cross- referenced notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.

Source

Authoritative
Federal Register document
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