Links to Official IRS Bulletin Documents listed below are in the Adobe Acrobat PDF Format, and require the appropriate Acrobat Reader to view and/or print.
T.D. 8767(PDF, 51K)
Final, temporary, and proposed regulations under section 954 of the Code relate to the treatment under subpart F of certain payments involving branches of a controlled foreign corporation (CFC) that are treated as separate entities for foreign tax purposes or partnerships in which CFCs are partners. A public hearing on the proposed regulations will be held on July 15, 1998.
T.D. 8765(PDF, 41K)
Final regulations under section 985 of the Code relate to adjustments required when a qualified business unit (QBU) that used the profit and loss method of accounting (P&L) in a post-1986 year begins to use the dollar approximate separate transaction method of accounting (DASTM) and adjustments required when a OBU that used DASTM begins using P&L.
Announcement 98-29(PDF, 23K)
A list is given of organizations now classified as private foundations.
Proposed regulations under sections 482 and 864 of the Code relate to rules for the allocation among controlled taxpayers and sourcing of income, deductions, gains and losses from a global dealing operation; rules applying these allocation and sourcing rules to foreign currency transactions and to foreign corporations engaged in a U.S. trade or business; and rules concerning the mark-to-market treatment resulting from hedging activities of a global dealing operation. A public hearing will be held on July 9, 1998.
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