Internal Revenue Bulletin: 2007-22 |
May 29, 2007 |
Table of Contents
Revenue rulings obsolete. This ruling obsoletes Rev. Rul. 74-245, 1974-1 C.B. 124, and Rev. Rul. 82-45, 1982-1 C.B. 89, which provide guidance regarding income subject to foreign legal restrictions (also known as blocked income) under section 482. Rev. Ruls. 74-245 and 82-45 obsoleted.
This revenue ruling obsoletes Rev. Rul. 74-245, 1974-1 C.B. 124, and Rev. Rul. 82-45, 1982-1 C.B. 89, which provide guidance regarding income subject to foreign legal restrictions (also known as blocked income). Rev. Ruls. 74-245 and 82-45 are not considered determinative with respect to future transactions. Guidance regarding income subject to foreign legal restrictions for purposes of section 482 is provided in § 1.482-1(h)(2) of the Income Tax Regulations (T.D. 8552, 1994-2 C.B. 93, 125). Therefore, Rev. Rul. 74-351, 1974-2 C.B. 144, does not provide guidance regarding income subject to foreign legal restrictions for purposes of section 482, but may provide guidance regarding income subject to foreign legal restrictions for other purposes.
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