Section 1503(d) denies us of the
losses of one domestic corporation by another affiliated domestic
corporation where the loss corporation is also subject to the
income tax of another country. The regulation allows an affiliate
to make use of the loss if the loss has not been used in the
foreign country and if an agreement is attached to the income tax
return of the dual resident corporation or group to take the loss
into income upon future use of the loss in the foreign country. The
regulation also requires separate accounting for a dual
consolidated loss where the dual resident corporation files
a....
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.