INCOME TAX

T.D. 9452, page 1. Final regulations under section 904 of the Code provide guidance relating to the application of section 904 to dividends paid by a foreign corporation that is a noncontrolled section 902 corporation as defined in section 904(d)(2)(E). The regulations also provide rules under section 964 for the election, adoption, or change of a method of accounting or taxable year on behalf of a foreign corporation by its controlling domestic shareholders.

Rev. Proc. 2009–31, page 107. This procedure provides guidance regarding the granting or revocation of consent to treat intercompany transactions on a separate entity basis under regulations section 1.1502–13(e)(3). Rev. Proc. 97–49 modified and superseded.