federal_register: 97-25997

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts
97-25997 Treaty-Based Return Positions Rule This document contains final regulations under section 6114 of the Internal Revenue Code of 1986 providing that reporting is specifically required if the residency of an individual is determined under a treaty and apart from the Code. The IRS concluded, in the process of completing the regulations under section 7701(b), that the rules of section 6114 should apply to individuals determining their residency under a treaty. These final regulations are necessary to implement the section 6114 rules to individuals determining their residency under a treaty. Also contained in this document are final regulations relating to section 7701(b) and conforming changes to regulations under sections 6038 and 6046. 1997-10-14 1997 10 https://www.federalregister.gov/documents/1997/10/14/97-25997/treaty-based-return-positions https://www.govinfo.gov/content/pkg/FR-1997-10-14/pdf/97-25997.pdf Mines Bureau; Treasury Department; Internal Revenue Service 290,497,254 This document contains final regulations under section 6114 of the Internal Revenue Code of 1986 providing that reporting is specifically required if the residency of an individual is determined under a treaty and apart from the Code. The IRS...

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