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Applicability dates : This regulation is applicable for tax returns whose original due date falls on or after January 1, 1988. FOR FURTHER INFORMATION CONTACT: Joan Thomsen, (202) 622-3850 (not a
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Regulation Section 1.901 26 CFR Part 1--Filing Requirements DATE: June 13, 1986, RESPECTIVE PARTIES: The parties to this case are The United States of America, The Department of the Treasury, The Government of the Commonwealth of Puerto Rico, and The Commonwealth of the Northern Mariana Islands. CASE NO: 8759 1 DATE: April 21, 1985, IN THE HIGH COURT OF JUSTICE STATE OF THE COUNTY: NAPERVILLE CASE NUMBER: 87-0524 SUPPLEMENTARY INFORMATION: This is the second time the District court has considered the Foreign Tax Credit for Puerto Rico, and both decisions have held that the Puerto Rico Act creates an exemption from tax imposed by section 613 of the Internal Revenue Code (the “Code”) for any interest income paid or accrued to, on account of, or in satisfaction of Puerto Rican tax imposed by the provisions of the Internal Revenue Code (the “Indecency and Immorality Tax Act”). In the present case, the District Court held that the Puerto Rico Act requires that the tax imposed by the Code be credited in the taxpayer's domestic income tax return. The District Court held that the “Act's purpose is to ensure that taxable income earned or accrued in Puerto Rico is not effectively excluded from the payment of United States income tax.” The District Court also held the Puerto Rico Act imposes a tax on interest, without a credit, for a period prior to the date of the Act's enactment. The District Court held the statute provides a sufficient exemption to permit the exclusion of interest paid or accrued to, on account of, and in satisfaction of Puerto Rican tax imposed by the provisions of the Code which may “prevent the timely settlement and payment of tax on the island's interest income.” These rulings by the District Court in this case are in accord with the decisions handed down by the District Court in Case No. 90-3058, U.S. v. W. J. E. S. C., 86 D.C. 565 (1985), and Case No. 90-9114, U.S. v. V. S. T. J. S. C., 87 D.C. 579 (1985), on the merits of that cases.

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TD 8759 is a tax form used to report certain transactions and activities to the Internal Revenue Service (IRS).
Certain taxpayers, such as financial institutions and businesses, may be required to file TD 8759. It is important to consult with a tax professional or refer to IRS guidelines to determine your specific filing requirements.
To fill out TD 8759, you will need to provide the required information as outlined by the IRS. This may include details about the transactions, parties involved, and any other relevant information. It is advisable to seek guidance from a qualified tax professional to ensure accurate and compliant completion of the form.
The purpose of TD 8759 is to provide information to the IRS about specific transactions or activities that may have tax implications. This form helps the IRS monitor and enforce compliance with tax laws.
The specific information required on TD 8759 varies depending on the nature of the transaction or activity being reported. It is crucial to refer to the instructions provided by the IRS for detailed guidance on reporting requirements.
The exact deadline to file TD 8759 in 2023 will be determined by the IRS. It is important to stay updated with IRS announcements and guidelines to ensure timely filing.
The penalty for late filing of TD 8759 may vary depending on various factors such as the duration of delay and the taxpayer's compliance history. It is recommended to review the IRS guidelines or consult with a tax professional to understand the specific penalty provisions.
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