Final, temporary, and proposed regulations under section 1561 of the Code affect component members of controlled groups and consolidated groups filing life-nonlife returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type of information these members are required to submit with their federal income tax returns.

Final, temporary, and proposed regulations under section 1561 of the Code affect component members of controlled groups and consolidated groups filing life-nonlife returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type of information these members are required to submit with their federal income tax returns.

This document contains corrections to final and temporary regulations (T.D. 9278, 2006-34 I.R.B. 256) regarding the treatment of controlled services transactions under section 482 of the Code and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party.

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations, notice of proposed rulemaking, and notice of public hearing (REG-146893-02, 2006-34 I.R.B. 317) regarding the treatment of controlled services transactions under section 482 of the Code and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party.

This document contains corrections to final and temporary regulations (T.D. 9260, 2006-23 I.R.B. 1001) concerning the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations under section 904(d)(4) of the Code.