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DEPARTMENT OF THE TREASURY Internal Revenue Service
public-inspection.federalregister.govand section 951A inclusions in the final section 951A regulations and the final regulations, regulations under section 871 apply the aggregate approach in applying the 10 percent shareholder test of section 871(h)(3) to determine whether interest paid to a partnership would be considered portfolio interest under section 871(h)(2). §1.871-
DEPARTMENT OF THE TREASURY Internal Revenue Service …
public-inspection.federalregister.govConcurrent with the issuance of the final section 951A regulations, the Treasury Department and the IRS published proposed regulations (REG-101828-19) under sections 951, 951A, 954, 956, 958, and 1502 in the Federal Register (84 FR 29114, as