For Tax Professionals  
T.D. 8669 October 08, 1996

Computation Of Combined Taxable Income Under the Profit
Split Method When the Possession Product Is a Component
Product or an End-Product Form for Purposes of the
Possessions Credit Under Section 936

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 8669] RIN 1545-AR18

TITLE: Computation of combined taxable income under the profit split method when the possession product is a component product or an end-product form for purposes of the possessions credit under section 936

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations relating to the computation of combined taxable income under the profit split method. These regulations amend the current regulations and provide revised rules for taxpayers to compute combined taxable income under the profit split method when the possession product chosen for purposes of section 936(h)(5) of the Internal Revenue Code is a component product or an end-product form. These regulations are necessary to provide guidance to taxpayers electing the profit split method of computing taxable income under section 936(h)(5).

DATES: These regulations are effective May 10, 1996. See SUPPLEMENTARY INFORMATION for applicability dates.

FOR FURTHER INFORMATION CONTACT: Jacob Feldman, 202-622-3870 (not a toll-free number).

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