TD 9315 - Section 1503(d) Closing Agreement Requests

ICR 201306-1545-054

OMB: 1545-1706

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2013-06-20
IC Document Collections
IC ID
Document
Title
Status
19189
Unchanged
ICR Details
1545-1706 201306-1545-054
Historical Active 201003-1545-010
TREAS/IRS
TD 9315 - Section 1503(d) Closing Agreement Requests
Extension without change of a currently approved collection   No
Regular
Approved without change 08/01/2013
Retrieve Notice of Action (NOA) 06/28/2013
  Inventory as of this Action Requested Previously Approved
08/31/2016 36 Months From Approved 07/31/2013
20 0 20
2,000 0 2,000
0 0 0

Revenue Procedure 2000-42 informs taxpayers of the information they must submit to request a closing agreement under Reg. S1.1503-2(g)(2)(iv)(B)(2)(i) to prevent the recapture of dual consolidated losses (DCLs) upon the occurrence of certain triggering events. TD 9315 contains final regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, the loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. These final regulations address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group.

US Code: 26 USC 1503 Name of Law: Computation and Payment of Tax
  
None

Not associated with rulemaking

  77 FR 73115 12/07/2012
78 FR 38446 06/26/2013
No

1
IC Title Form No. Form Name
TD 9315 - Section 1503(d) Closing Agreement Requests

  Total Approved Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 20 20 0 0 0 0
Annual Time Burden (Hours) 2,000 2,000 0 0 0 0
Annual Cost Burden (Dollars) 0 0 0 0 0 0
No
No

$0
No
No
No
No
No
Uncollected
Kay Holmes 202 622-3269

  No

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.
06/28/2013


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