2003 Proposed Regulations
REG–133791–02 and REG–105606–99: Notice of proposed rulemaking;
Published in the Federal Register on July 29, 2003 – REG–133791–02 and REG-105606-99.
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG–133791–02 and REG–105606–99]
RINS 1545–BA88 1545–AX05
Credit for Increasing Research Activities
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; notice of public hearing; and withdrawal of previously proposed regulations.
SUMMARY: This document contains proposed regulations relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control.
These proposed regulations reflect changes made to section 41 by the Revenue Reconciliation Act of 1989 and the Small Business Job Protection Act of 1996, which introduced the alternative incremental research credit. This document also provides notice of a public hearing on these proposed regulations and withdraws the proposed regulations published in the Federal Register on January 4, 2000 (65 FR 258).
DATES: Written or electronic comments must be received by October 27, 2003. Requests to speak and outlines of the topics to be discussed at the public hearing scheduled for November 13, 2003 at 10 a.m. must be received by October 23, 2003.
ADDRESSES: Send submissions to: CC:PA:RU (REG–133791–02), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may also be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to: CC:PA:RU (REG–133791–02), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, DC 20224. Alternatively, taxpayers may submit comments electronically via the Internet by submitting comments directly to the IRS Internet site at: http://www.irs.gov/regs.
The public hearing will be held in the IRS Auditorium (7th Floor), Internal Revenue Building, 1111 Constitution Avenue, NW., Washington, DC 20224.
FOR FURTHER INFORMATION CONTACT: Concerning these proposed regulations, Jolene J. Shiraishi at (202) 622–3120 (not a toll-free call); concerning submissions of comments, the hearing, and to be placed on the building access list to attend the hearing, Guy Traynor at (202) 622–7180 (not a toll-free call).
SUPPLEMENTARY INFORMATION:
Background
Summary of Comments and Explanation of Provisions
Overview
Computation of the Group Credit
Allocation of the Group Credit Among Members of the Controlled Group
2000 Proposed Regulations
Comments on the 2000 Proposed Regulations
Proposed Allocation Rule
Special Allocation Rule for Consolidated Groups
Effective Date
Special Analyses
List of Subjects in 26 CFR Part 1
WITHDRAWAL OF PROPOSED AMENDMENTS TO THE REGULATIONS
PROPOSED AMENDMENTS TO THE REGULATIONS
PART 1—INCOME TAXES
