Section 1503(d) denies the use of the
losses of one domestic corporation by another affiliated domestic
corporation where the loss corporation is also subject to the
income tax of a foreign country. This final regulation permits the
domestic use of the loss if the loss has not been used in the
foreign country provided a domestic use agreement is filed with the
income tax return of the domestic affiliated group or domestic
owner agreeing to recapture the loss into income upon a future
foreign use of the loss.
US Code:
26
USC 1503 Name of Law: Computation and payment of tax
US Code: 26
USC 6103 Name of Law: Confidentiality and disclosure of returns
and return information
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.