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Introduction

SECTION 1. OVERVIEW

Internal Revenue Bulletin 2010-22 · 2026-10-03 edition · updated 2026-10-04 · United States

The Treasury Department and Internal Revenue Service (IRS) intend to issue regulations that will classify certain domestic partnerships as foreign for purposes of identifying the United States shareholders (as defined in § 951(b) of the Internal Revenue Code (Code)) of a controlled foreign corporation (as defined in § 957(a)) that are required to include in gross income the amounts specified under § 951(a) of such controlled foreign corporation. The regulations to be issued pursuant to this notice shall apply to taxable years of a domestic partnership ending on or after May 14, 2010.

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▸Contents — Internal Revenue Bulletin 2010-22
Internal Revenue Bulletin 2010-22

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