May 2, 2011 . corresponding rules of §1.367(a)–8T (see. 26 CFR part 1, . rules of this

1.367(b)-8—Allocation of earnings and profits and foreign income taxes in .

ง1.367(a)-8.20. Under this agreement, the U.S. transferor agrees to recognize the

Section Remove Add 1.367(a)-3(d)(3), Example l(ii), fourth sentence §1.367(a)-8(

Feb 19, 2010 . 1.367(a)-8.11 Under a GRA, the. U.S. transferor agrees to include in income the

8 In practice, this generally means that at least 40 percent of the total .

Temp. Reg. 1.367(a)-8T(e)(3)(iv), . §1.367(a)-3(b)(1) are satisfied, and UST

§§1.367(a)-3 and 1.367(a)-8, affecting U.S. persons that transfer stock or

May 5, 2008 . 309. Internal Revenue Service, Treasury. § 1.367(a)–8T the .

Nov 3, 2011 . 1.367(b)-2 Definitions and special rules. .

1.367(a)-8T(d)(8). Who Must File. A United States transferor must file Form 8838 (

Title: Section 1.367(a)-8 Revisions to Gain Recognition Agreement Requirements

There is no nomenclature in -3(d)(2) or §1.367(a)-8T for F3. . .. §1.367(a)-8T(

May 14, 2007 . 309. Internal Revenue Service, Treasury. § 1.367(a)–8T consolidated return for

งง1.367(a)-3T,. -8T. These temporary regulations updated and modernized the

See §1.367(a)-8T(g)(2). If each asset transferred qualifies for . required

Reg. section 1.367(a)-8 outlines when a GRA will be triggered or terminated.

Oct 20, 2011 . As a result of the disposition of the TFC stock pursuant to the asset

Mar 13, 2009 . §1.367(a)-8T regulations to stock transfers occurring before March 13, . . §

May 8, 2008 . 8 See generally, Reg. § 1.367(a)-3(b) (transfers of foreign stock or . .. and (

sections 1.367(a)-8(a)(3) and 1.367(a)-8T(a)(3). Attorney or Agent. If you are an

Oct 17, 2005 . Treasury Regulation § 1.367(a)-8(e)(1) and (2) provides that dispositions of the

Title 26--Internal Revenue. CHAPTER I--INTERNAL REVENUE .

Jan 14, 2010 . If Form 8838 is filed by a successor U.S. transferor because of a transaction

If, however, UST complies with the requirements contained in Treas. Reg. §1.367(

§1.367(a)-3 384, Reg. §1.863-3 71-72, 80 386-387 Prop. Reg. §1.863-8 80 Reg.

1.367(a)-8 Gain recognition agreement requirements. . 1.367(b)-8 .

Mar 13, 2009 . §1.367(a)-8T regulations to stock transfers occurring before March 13, . . §

sections 1.367(a)-8(9(2)(i) and 1.367(a)-3T(e). The domestic corporation and

第1.367 （ a ）－ 8T 节资本利得确认协议的要求（暂行）. 翻译：李凯更、何清 . 也包括

International Tax Services www.andrewmitchel.com. Temp. Reg. 1.367(a)-8T(e)(

Apr 29, 2010 . 1.367(a)–8 provides exceptions for certain events . . 1.367(a)–8 avoid the

1.367(a)-8T (b)(3)(iv), TFC would recognize $35 of gain under section 351(b). X

that “were not already effective” under the prior Reg. §1.367(a)-8 regulations. 9.

Feb 11, 2009 . The collections of information in these final regulations are in § 1.367(a)-8(d), (g),

26 CFR 1.367(a)-8 - Gain recognition agreement requirements. - Code of Federal

triggering events. If, however, UST complies with the requirements contained in

This paragraph (h) (2) (i) applies only to rules in this regulation § 1.367(a)-8T that

§1.367(a)-8.13 Pursuant to a GRA, the U.S. transferor agrees, among other

1.367(a)-8T(e)(6)(ii), Example (Outbound 351, 332 Liquidation & Disposition .

The rules of §1.367(a)-8 apply because the gain recognition agreement was .

Nov 12, 2009 . Treas. Reg. § 1.367(a)-8(b) of the final regulations provides definitions and

Section t.367(a)~8 is revised to read as follows: §1.367(a)-8 Gain recognétion

DC1 properly files a gain recognition agreement under §1.367(a)–8 to qualify for

Feb 5, 2007 . [The text of proposed Sec. 1.367(a)8 is the same as the text of Sec. 1.367(a)8T

§§1.367(a)-3 and 1.367(a)-8, affecting U.S. persons that transfer stock or

This paragraph (h)(2)(i) applies only to rules in this regulation §1.367(a)-8T that

Mar 2, 2009 . The collections of information in these final regulations are in §1.367(a)-8(d), (g),

Apr 29, 2010 . were not included in §1.367(a)–8T (see 26 . lation § 1.367(a)–8 that were not

The gain recognition agreement must be entitled “GAIN RECOGNITION AGREEMENT

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