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SUMMARY: The IRS has announced that regulations will be issued identifying certain stock of a foreign corporation that is not taken into account to determine ownership of the foreign corporation for purposes of Code Sec. 7874(a)(2)(B)(ii).
TOPIC: Foreign Tax Issues
SECTION: 7874. Rules relating to expatriated entities and their foreign parents
CITATION: Notice 2009-78, I.R.B. 2009-40, September 17, 2009
DATE: 2009-09-16
DOC TYPE: Notice
EXPLANATION:
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