Skip to content

�������������›��������������������������������������������������������� �

SECTION 12. INTERNATIONAL ISSUES—CONTINUED

Internal Revenue Bulletin 2001-47 · 2026-10-03 edition · updated 2026-10-04 · United States

Statute or
Regulation
Act Postponed
31.

Sec. 991 and
Treas. Reg.
§ 1.991-
1(g)(2)
A corporation that filed a tax return as a DISC, but subsequently determines that it does not
wish to be treated as a DISC, must notify the [district director] more than 30 days before
the expiration of period of limitations on assessment applicable to the tax year.
32.

Sec. 992 and
Treas. Reg.
§ 1.992-
2(a)(1)(i)
A qualifying corporation must file Form 4876-A, or attachments thereto, containing the
consent of every shareholder of the corporation to be treated as a DISC as of the beginning
of the corporation's first taxable year.
33.

Sec. 992 and
Treas. Reg.
§ 1.992-
2(b)(2)
A qualifying corporation must file consents of the shareholders of the corporation to be
treated as a DISC with the service center with which the DISC election was first filed,
within 90 days after the first day of the taxable year, or within the time granted for an
extension to file such consents.
34.

Sec. 992 and
Treas. Reg.
§ 1.992-
2(e)(2)(ii)

A corporation seeking to revoke a prior election to be treated as a DISC, must file a state-
ment within the first 90 days of the taxable year in which the election is to take effect with
the service center with which it filed the election or, if the corporation filed an annual
information return, by filing the statement at the service center with which it filed its most
recent annual information return.
35.
Sec. 992 and
Treas. Reg.
§ 1.992-
3(c)(3)

A DISC that receives notification that it failed to satisfy the 95 percent of gross receipts test
or the 95 percent assets test, or both tests, for a particular taxable year, must make a correc-
tive deficiency distribution within 90 days of the date of the first written notification from
the IRS.
36.

Sec. 993 and
Treas. Reg.
§ 1.993-
3(d)(2)(i)(b)

A taxpayer must deliver export property outside the U.S. within one year of the date of sale
or lease in order to generate DISC benefits from a qualifying export transaction.
37.

Sec. 1445
Treas. Reg.
§ 1.1445-1
Form 8288, U.S. Withholding Tax Return for Dispositions by Foreign Persons of U.S. Real
Property Interests, must be filed by a buyer or other transferee of a U.S. real property inter-
est, and a corporation, partnership, or fiduciary that is required to withhold tax. The
amount withheld is to be transmitted with Form 8288, which is generally to be filed by the
20th day after the date of transfer.
38.
Sec. 1446

All partnerships with effectively connected gross income allocable to a foreign partner in
any tax year must file forms 8804, Annual Return for Partnership Withholding Tax, and
8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax, on or
before the 15th day of the 4th month following the close of the partnership's taxable year.
39.
Sec. 1446

Form 8813, Partnership Withholding Tax Payment Voucher, is used to pay the withhold-
ing tax under section 1446 for all partnerships with effectively connected gross income
allocable to a foreign partner in any tax year. Form 8813 must accompany each payment
of section 1446 tax made during the partnership’s taxable year. Form 8813 is to be filed on
or before the 15th day of the 4th, 6th, 9th, and 12th months of the partnership's taxable year
for U.S. income tax purposes.
40. Sec.
6038A(d)(2)
and Treas.
Reg.
§ 1.6038A-
4(d)(1)

A reporting corporation must cure any failure to furnish information or failure to maintain
records within 90 days after the IRS gives notice of the failure to avoid the continuation
penalty.

������������������ ���� ���������������

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Bulletin 2001-47

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.