Internal Revenue Bulletins  

April 20, 1998

Internal Revenue Bulletin No. 1998-16

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)
REG-104537-97(PDF, 39K)
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.


REG-208299-90(PDF, 127K)
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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