attribution rules

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1 headnote for attribution rules

- Attribution rules Taxation

3.908 documents for attribution rules

- 12 CFR 614.4359 - Attribution rules.
- Code of Federal Regulations - Title 12: Banks and Banking
- Attribution rules applicable to commercial activities or controlled commercial entities of a foreign government for sec. 163(j) purposes.
Careful reading of IRC section 892(a)(3) appears to indicate that foreign governments can be considered as persons under the US laws on the tax treatment of transactions involving foreign persons subject to US taxation. The IRS has expanded the reach of the ownership attribution rules contained under IRC section 163(j) and other sections, but it has failed to provide guidance on how these rules could affect certain affiliated groups. A foreign industry that is state-supported and that involves many members could give rise to many related party transactions under the broader attribution rules.
- The Tax Adviser
- Vol. 26 Nbr. 6, June 1995
- 26 CFR 1.509(a)-5 - Special rules of attribution.
- Code of Federal Regulations - Title 26: Internal Revenue

- 'Calm' Holds, but Angst Rampant ; Hamas Seen As 'Big Winner' in Israeli Truce
As the Israel-Hamas cease-fire held for a fourth day Sunday, many in the Jewish state feared that the Islamic militant group had begun to achieve international credibility despite its vow to destroy Israel. Israel on Sunday boosted supplies of food and medicine going into the Gaza Strip by about 50 percent and said it's considering further relaxations of the months-long siege on the war-weary enclave, a military official said on the condition of anonymity because of rules forbidding comment for attribution.
- The Washington Times
- June 23, 2008
- 2010 Quadrennial Regulatory Review
In this document, section 202(h) of the Telecommunications Act of 1996 requires the Commission to review its broadcast ownership rules quadrennially to determine whether these rules are necessary in the public interest as a result of competition. This document solicits comment on proposed changes to the broadcast ownership rules in compliance with this requirement. In addition, this document solicits comment on certain aspects of the Commission's 2008 Diversity Order that the U.S. Court of Appeals for the Third Circuit remanded and directed the Commission to address in this proceeding. This document solicits comment also on potential changes to the Commission's broadcast attribution rules.
- Federal Register Nbr. 77 FR 2868, January 19, 2012
- Proposed rules
- Federal Communications Commission
- United States v. Davis, 397 U.S. 301 (1970)
...'s finding that, by reason of the rules of attribution in 318 (a) of the Code (under which...
- U.S. Supreme Court
- Radio broadcasting: ownership attribution rules; regulatory review,
- FR, September 17, 1999
- Rules
- Federal Communications Commission
- Television broadcasting: Ownership attribution rules,
- FR, February 13, 2001
- Rules
- Federal Communications Commission
- INTERNATIONAL DEVELOPMENTS: Taxation Of Passive Foreign Investment Companies: Current Rules, Problems And Possible Solutions.
... as the owner of PFIC stock.9 The attribution rules, however, do not apply to treat stock owned ...
- Mondaq Business Briefing
- Nbr. 2011, January 2011
- Television broadcasting: Cable television systems Ownership attribution rules,
- FR, July 14, 1998
- Proposed rules
- Federal Communications Commission