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772 KB
Extraction Summary
1
People
4
Organizations
1
Locations
1
Events
0
Relationships
2
Quotes
Document Information
Type:
Legal/financial research report (footnotes/endnotes)
File Size:
772 KB
Summary
This document is a page of footnotes (citations 73-85) from a legal or financial report produced by Thomson Reuters/RIA in 2009, bearing a House Oversight Bates stamp. The text focuses on U.S. tax regulations, specifically Dual Consolidated Loss (DCL) rules, Disregarded Entities (DREs), and Treasury Department proposals. It references a May 4, 2009, news conference by President Obama regarding tax havens.
People (1)
| Name | Role | Context |
|---|---|---|
| President Obama | President of the United States |
Announced a proposal regarding combating tax havens during a news conference on 5/4/09.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| IRS |
Internal Revenue Service; mentioned regarding rules treating a DRE as separate from its sole owner.
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|
| Dept. of Treasury |
Source of General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals.
|
|
| Thomson Reuters/RIA |
Copyright holder of the document content.
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT'.
|
Timeline (1 events)
2009-05-04
Locations (1)
| Location | Context |
|---|---|
|
Implied by mentions of U.S. parent, IRS, and Dept. of Treasury.
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Key Quotes (2)
"The DCL rules also specifically speak about situations involving "transparent entities," which are uniquely defined for purposes of the DCL rules."Source
HOUSE_OVERSIGHT_026597.jpg
Quote #1
"President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens."Source
HOUSE_OVERSIGHT_026597.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (978 characters)
73
See Reg. 1.1503(d).
See Reg. 1.1503(d).
74
Reg. 1.1503(d)-1(b)(3).
Reg. 1.1503(d)-1(b)(3).
75
TD 9315, 3/16/07.
TD 9315, 3/16/07.
76
Reg. 1.1503(d)-1(b)(2).
Reg. 1.1503(d)-1(b)(2).
77
TD 9315, 3/16/07.
TD 9315, 3/16/07.
78
Id.; Section 1503(d)(1). The DCL rules also specifically speak about situations involving "transparent entities," which are uniquely defined for purposes of the DCL rules.
Id.; Section 1503(d)(1). The DCL rules also specifically speak about situations involving "transparent entities," which are uniquely defined for purposes of the DCL rules.
79
See generally Reg. 1.1503(d)-5.
See generally Reg. 1.1503(d)-5.
80
There are also other narrow areas where the IRS has indicated it will treat a DRE as separate from its sole owner, such as the foreign exchange rules under Section 987 in the case of certain DREs that are qualified business units and have a different functional currency than their U.S. parent.
There are also other narrow areas where the IRS has indicated it will treat a DRE as separate from its sole owner, such as the foreign exchange rules under Section 987 in the case of certain DREs that are qualified business units and have a different functional currency than their U.S. parent.
81
See Dept. of Treasury, General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (May 2009).
See Dept. of Treasury, General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (May 2009).
82
President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens.
President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens.
83
See supra footnote 77.
See supra footnote 77.
84
Id.
Id.
85
Id.
Id.
© 2009 Thomson Reuters/RIA. All rights reserved.
HOUSE_OVERSIGHT_026597
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