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1.02 MB
Extraction Summary
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Document Information
Type:
Legal/tax report (endnotes/footnotes page)
File Size:
1.02 MB
Summary
This document page contains a list of endnotes (citations 24 through 39) from a larger legal or financial report produced for the House Oversight Committee. The text focuses on technical federal tax regulations regarding 'disregarded entities,' grantor trusts, and Qualified REIT Subsidiaries (QRSs). It cites various Treasury Regulations (Reg./TD) and IRS publications dating between 1999 and 2009.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Internal Revenue Service (IRS) |
Cited in regulations and publications (e.g., IRS Publication 15).
|
|
| House Oversight Committee |
Source of the document (Bates stamp HOUSE_OVERSIGHT_026594).
|
Key Quotes (3)
"The Notice did not specifically mention grantor trusts or QRSs, but its stated purpose was to address issues related to entities 'disregarded as entities separate from their owners for federal tax purposes.'"Source
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Quote #1
"The issuance of the final regulations made Notice 99-6 obsolete as of 1/1/09."Source
HOUSE_OVERSIGHT_026594.jpg
Quote #2
"Grantor trusts are not covered by these provisions."Source
HOUSE_OVERSIGHT_026594.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,288 characters)
1999-1 CB 321. The Notice did not specifically mention grantor trusts or QRSs, but its stated purpose was to address issues related to entities "disregarded as entities separate from their owners for federal tax purposes." While it was clearly intended to respond to the then recently enacted check-the-box regulations and QSub rules, the Notice should also have applied to grantor trusts and QRSs—but it would be unusual for a grantor trust or QRS to have employees.
24
Id.
Id.
25
REG-114371-05, 10/18/05.
REG-114371-05, 10/18/05.
26
TD 9356, 8/15/07. The issuance of the final regulations made Notice 99-6 obsolete as of 1/1/09.
TD 9356, 8/15/07. The issuance of the final regulations made Notice 99-6 obsolete as of 1/1/09.
27
Reg. 301.7701-2(a) references these special employment and excise tax rules.
Reg. 301.7701-2(a) references these special employment and excise tax rules.
28
Reg. 301.7701-2(c)(2)(iv)(C), Example ii.
Reg. 301.7701-2(c)(2)(iv)(C), Example ii.
29
Reg. 301.7701-2(c)(2)(iv)(A).
Reg. 301.7701-2(c)(2)(iv)(A).
30
Reg. 301.7701-2(e)(5).
Reg. 301.7701-2(e)(5).
31
IRS Publication 15, Employer's Tax Guide (3/09).
IRS Publication 15, Employer's Tax Guide (3/09).
32
Reg. 301.7701-2(c)(2)(v).
Reg. 301.7701-2(c)(2)(v).
33
See Reg. 301.7701-2(c)(2)(v) for a list of relevant excise taxes and associated exceptions.
See Reg. 301.7701-2(c)(2)(v) for a list of relevant excise taxes and associated exceptions.
34
Reg. 301.7701-2(e)(6).
Reg. 301.7701-2(e)(6).
35
Regs. 1.1361-4(a)(7) and (8).
Regs. 1.1361-4(a)(7) and (8).
36
Id.
Id.
37
Regs. 1.1361-4(a)(7)(ii) and (8)(ii).
Regs. 1.1361-4(a)(7)(ii) and (8)(ii).
38
Regs. 301.7701-2(c)(2)(iii)(A), 1.1361-4(a)(6), and 1.856-9. Grantor trusts are not covered by these provisions.
Regs. 301.7701-2(c)(2)(iii)(A), 1.1361-4(a)(6), and 1.856-9. Grantor trusts are not covered by these provisions.
39
Regs. 301.7701-2(e)(2), 1.1361-4(a)(6)(iii), and 1.856-9(c).
Regs. 301.7701-2(e)(2), 1.1361-4(a)(6)(iii), and 1.856-9(c).
HOUSE_OVERSIGHT_026594
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