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Treaty-Based Return Positions

tax-irs · IRS · Rule · Published 1997-10-14 · Effective 1997-12-15 · 62 FR 53384

Document

Document number
97-25997
Federal Register citation
62 FR 53384
Type
Rule
Action
Final regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
1997-10-14
Effective date
1997-12-15
Treasury docket
TD 8733

Abstract

This document contains final regulations under section 6114 of the Internal Revenue Code of 1986 providing that reporting is specifically required if the residency of an individual is determined under a treaty and apart from the Code. The IRS concluded, in the process of completing the regulations under section 7701(b), that the rules of section 6114 should apply to individuals determining their residency under a treaty. These final regulations are necessary to implement the section 6114 rules to individuals determining their residency under a treaty. Also contained in this document are final regulations relating to section 7701(b) and conforming changes to regulations under sections 6038 and 6046.

Source

Authoritative
Federal Register document
Machine
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