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2010-09-23
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Treaty Guidance Regarding Payments With Respect to Domestic Reverse Hybrid Entities
Rules and Regulations
D09002ee1bdee7e2a
D09002ee1bdeea792
United States
Department of the Treasury
originator
org
United States Government Agency or Subagency
United States
Internal Revenue Service
originator
org
United States Government Agency or Subagency
This document contains final regulations under section 894 relating to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. law but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (domestic reverse hybrid entities). The regulations affect the determination of tax treaty benefits with respect to U.S. source income of foreign persons.
67 FR 40157
https://www.govinfo.gov/app/details/FR-2002-06-12/02-14506
02-14506
fr12jn02-6
RIN 1545-AY13
4830-01-P
TD 8999
https://www.govinfo.gov/app/details/FR-2002-06-12/02-14506
https://www.govinfo.gov/content/pkg/FR-2002-06-12/html/02-14506.htm
https://www.govinfo.gov/content/pkg/FR-2002-06-12/pdf/02-14506.pdf
Income Taxes
Reporting and Recordkeeping Requirements
6 p.
40157
40162
67 FR 40157
Code of Federal Regulations
Title 26 Part 1
26 CFR Part 1
Regulation Identification Number 1545-AY13
RIN 1545-AY13
Treaty Guidance Regarding Payments With Respect to Domestic Reverse Hybrid Entities; Federal Register Vol. 67, Issue
RULE
02-14506
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2002-06-12
TD 8999
4830-01-P
02-14506
Final regulations.
This document contains final regulations under section 894 relating to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. law but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (domestic reverse hybrid entities). The regulations affect the determination of tax treaty benefits with respect to U.S. source income of foreign persons.
Effective Date: These regulations are effective June 12, 2002.
Elizabeth U. Karzon at (202) 622-3880 (not a toll-free number).
Income Taxes
Reporting and Recordkeeping Requirements
Income taxes:
Domestic reverse hybrid entities; treaty guidance regarding payments,
Federal Register
Vol. 67, no. 113
Office of the Federal Register, National Archives and Records Administration
2002-06-12
continuing
daily
deposited
born digital
455 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2002-06-12
P0b002ee1809bf725
0097-6326
0042-1219
0364-1406
769-004-00000-9
000582072
f:fr12jn02
https://www.govinfo.gov/app/details/FR-2002-06-12
https://www.govinfo.gov/content/pkg/FR-2002-06-12/pdf/FR-2002-06-12.pdf
https://www.govinfo.gov/content/pkg/FR-2002-06-12/xml/FR-2002-06-12.xml
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40137
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DGPO
2010-09-23
2023-05-04
FR-2002-06-12
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eng
FR
FR-2002-06-12
67
113