Skip to main content
Skip to content
Case File
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
1
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

Ask AI About This Document

0Share
PostReddit
Review This Document

Extracted Text (OCR)

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.

Related Documents (6)

House OversightUnknown

Speculative analysis of Obama’s stance on Iran and Israel‑Palestine

Speculative analysis of Obama’s stance on Iran and Israel‑Palestine The passage offers only broad political commentary without concrete names, transactions, dates, or actionable leads. It repeats well‑known public positions and does not introduce new evidence or specific allegations involving high‑ranking officials. Key insights: Suggests Obama may discuss Israel‑Palestine and Iran issues privately with Israeli leaders; Notes past Obama‑Netanyahu tensions over Iran policy; Poses questions about Obama’s possible regime‑change vs. nuclear‑deal agenda

1p
House OversightUnknown

Opinion piece questioning Obama’s foreign‑policy strategy and military decisions

Opinion piece questioning Obama’s foreign‑policy strategy and military decisions The passage offers only vague criticism of President Obama’s use of force with no specific dates, transactions, or actionable leads. It mentions a senior foreign‑policy official (Robert D. Blackwill) but provides no concrete allegation, financial flow, or wrongdoing to pursue. Key insights: Critiques Obama’s lack of a clear strategic framework for military force.; Cites perceived missteps in Iraq, Afghanistan, and Libya.; Names Robert D. Blackwill, former deputy national security adviser and CFR senior fellow.

1p
DOJ Data Set 9OtherUnknown

From: Office of Terje Rod-Larsen

21p
House OversightUnknown

President Trump discusses Bob Woodward interview on phone, claims staff ignorance

President Trump discusses Bob Woodward interview on phone, claims staff ignorance The passage provides a brief anecdote of Trump’s phone call with journalist Bob Woodward, noting a claim that White House staff failed to inform him of the interview request. While it mentions a high‑profile figure (President Trump) and a senior aide (Kellyanne Conway), it lacks concrete details about wrongdoing, financial flows, or actionable leads. The information is already publicly reported and offers little novel investigative value. Key insights: Trump claims his staff did not tell him Woodward wanted an interview.; Kellyanne Conway is referenced as having asked Trump about a call.; Trump characterizes Woodward as "always been fair" but later calls the book inaccurate.

1p
Dept. of JusticeOtherUnknown

EFTA Document EFTA01380343

Name allreitsklp Present Principal Occupation or Employment John J. Donahoe United States Function: Director. Board of Directors; Chair, Executive Committee; Co-Chair, Corporate Governance and Nominating Committee Professional Background: John Donahoe was elected to the Intel board of directors in March 2009. Donahoe has served as chairman of the board of PayPal Holdings Inc.. a technology platform company, since July 2015. He was president and CEO of eBay Inc., a global e- commerce co

1p
House OversightOtherNov 11, 2025

Bill Siegel email chain discussing 'The Control Factor' and anti‑Islamic conspiracy narrative

The passage is an internal email and interview transcript promoting a conspiratorial worldview about 'Islamic Enemy' and 'Civilization Jihad.' It mentions Jeffrey Epstein as a sender but provides no c Email originates from Jeffrey Epstein's address, but only contains a casual invitation and a link to Bill Siegel outlines a theory called the 'Control Factor' that frames Islam as a coordinated threa

20p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,500+ persons in the Epstein files. 100% free, ad-free, and independent.

Support This ProjectSupported by 1,550+ people worldwide
Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.