TD 9451 - Guidance Necessary To Facilitate Business Election Filing; Finalization of Controlled Group Qualification Rules, TD 9759-Limitations on the Importation of Net Built-In Losses
TD 9451 - Guidance Necessary To Facilitate Business Election Filing; Finalization of Controlled Group Qualification Rules, TD 9759-Limitations on the Importation of Net Built-In Losses
Extension without change of a currently approved collection
TD 9304 provides guidance to taxpayers regarding the apportionment of tax benefit items under section 1561(a) amongst the component members of a controlled group of corporations. TD 9329 contains final regulations that simplify, clarify, or eliminate reporting burdens and also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their Federal income tax returns. TD 9451 provides guidance to taxpayers for determining which corporations are included in a controlled group of corporations. TD 9759 provides guidance for preventing the importation of loss when a corporation that is subject to U.S. income tax acquires loss property tax-free in certain transactions and the loss in the acquired property accrued outside the U.S. tax system by requiring the bases of the assets received to be equal to value.
US Code:
26 USC 362
Name of Law: Basis to corporations
US Code:
26 USC 334
Name of Law: Basis of property received in liquidations
US Code:
26 USC 7805
Name of Law: Rules and regulations
US Code:
26 USC 1561
Name of Law: Limitation on accumulated earnings credit in the case of certain controlled corporations
US Code:
26 USC 1563
Name of Law: Definitions and special rules
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
2025 Supporting Statement (1545-2019) (2).docx
TD 9759 - Limitations on the Importation of Net Built-In Losses