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Agent for a Consolidated Group With Foreign Common Parent

tax-irs · IRS · Rule · Published 2006-03-14 · Effective 2006-03-14 · 71 FR 13001

Document

Document number
06-2438
Federal Register citation
71 FR 13001
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2006-03-14
Effective date
2006-03-14
Treasury docket
TD 9255

Abstract

This document contains temporary regulations under section 1502 that provide the IRS with the authority to designate a domestic member of the consolidated group as a substitute agent to act as the sole agent for the group where a foreign entity is the common parent. The regulations affect corporations that join in the filing of a consolidated Federal income tax return where the common parent of the consolidated group is a foreign entity that is treated as a domestic corporation pursuant to section 7874(b) of the Internal Revenue Code (Code) or as the result of a section 953(d) election. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.

Source

Authoritative
Federal Register document
Machine
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