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d-29480House OversightOther

Regulatory citations on DCL rules and IRS treatment of DREs, with reference to President Obama's 2009 tax haven proposal

The passage mainly lists regulatory references and a brief mention of President Obama announcing a tax‑haven proposal in 2009. It provides no concrete leads, names, transactions, or novel allegations Cites Treasury Reg. 1.1503(d) and related subsections concerning "transparent entities". Notes IRS treatment of Disregarded Entities (DREs) under Section 987 for foreign exchange rules. References Pr

Date
November 11, 2025
Source
House Oversight
Reference
House Oversight #026597
Pages
1
Persons
0
Integrity
No Hash Available

Summary

The passage mainly lists regulatory references and a brief mention of President Obama announcing a tax‑haven proposal in 2009. It provides no concrete leads, names, transactions, or novel allegations Cites Treasury Reg. 1.1503(d) and related subsections concerning "transparent entities". Notes IRS treatment of Disregarded Entities (DREs) under Section 987 for foreign exchange rules. References Pr

Tags

tax-lawregulatory-referencetax-havenspolicy-announcementhouse-oversightregulationsirsobama-administrationtransparent-entities
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Browse House Oversight Committee ReleasesHouse Oversight #026597

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
73 See Reg. 1.1503(d). 74 Reg. 1.1503(d)-1(b)(3). 75 TD 9315, 3/16/07. 76 Reg. 1.1503(d)-1(b)(2). “TE TD 9315, 3/16/07. 78 Id.; Section 1503(d)(1). The DCL rules also specifically speak about situations involving “transparent entities,” which are uniquely defined for purposes of the DCL rules. WLS) See generally Reg. 1.1503(d)-5. 80 There are also other narrow areas where the IRS has indicated it will treat a DRE as separate from its sole owner, such as the foreign exchange rules under Section 987 in the case of certain DREs that are qualified business units and have a different functional currency than their U.S. parent. 81 See Dept. of Treasury, General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (May 2009), 82 President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens. 83 See supra footnote 77. © 2009 Thomson Reuters/RIA. All rights reserved.

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