Document Type

Article

Publication Date

12-1-2005

Abstract

Part 1 of this article in the October issue reviewed the final Regulations under Section 1446 of the Internal Revenue Code published by the IRS in the federal Register on May 18, 2005.2 In this second part, we review the Temporary Regulations (also TD 9200) and Proposed Regulations (REG-108524-00, with cross-reference to TD 9200) issued at the same time and redeem our promise to offer some comments on the future of this tangled area of the law.

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