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RULES: Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction,
Published: 2008-04-03
This document contains a correction to final and temporary
regulations (TD 9383) that were published in the Federal Register on Friday, March 7, 2008 (73 FR 12265).
Concerning the treatment of certain intercompany gain with respect
to consolidated group member stock. These amendments provide for the
redetermination of an intercompany gain as
RULES: Guidance Under Section 1502; Succession to Items of Liquidating Corp.,
Published: 2008-01-15
This document contains final regulations under section 1502 of
the Internal Revenue Code that provide guidance regarding the manner in
which the items (including items described in section 381(c) but
excluding intercompany items under Sec. 1.150213) of a liquidating
corporation are succeeded to and taken into account in cases in which
multiple
PROPOSED RULES: Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures and Partnership Organizational Expenses,
Published: 2008-07-08
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations relating to
the elections to deduct startup expenditures under section 195 of the
Internal Revenue Code (Code), organizational expenditures of
corporations under section 248, and organizational expenses of
partnerships under section
RULES: S Corporation Guidance Under AJCA of 2004 and GOZA of 2005; Correction,
Published: 2008-09-24
This document contains a correction to final regulations (TD
9422) that were published in the Federal Register on Thursday, August 14, 2008 (73 FR 47526) providing guidance
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regarding certain changes made to the rules governing S corporations
under the American Jobs Creation Act of 2004 and the Gulf Opportunity
Zone Act of 2005. The
PROPOSED RULES: Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions,
Published: 2008-11-28
This document provides notice of public hearing on proposed
regulations relating to the substantiation and reporting requirements
for cash and noncash charitable contributions under section 170 of the
Internal Revenue Code. The regulations reflect the enactment of
provisions of the American Jobs Creation Act of 2004 and the Pension
Protection Act
RULES: Stock Transfer Rules; Carryover of Earnings and Taxes; Correction,
Published: 2008-03-18
This document contains a correction to final regulations (TD
9273) that were published in the Federal Register on Tuesday, August 8,
2006 (71 FR 44887) addressing the carryover of certain tax attributes,
such as earnings and profits and foreign income tax accounts, when two
corporations combine in a corporate reorganization or liquidation that
is
RULES: Guidance Under Section 7874 for Determining the Ownership Percentage in the Case of Expanded Affiliated Groups,
Published: 2008-05-20
This document contains final regulations under section 7874 of
the Internal Revenue Code (Code) relating to the disregard of certain
affiliateowned stock in determining whether a corporation is a
surrogate foreign corporation under section 7874(a)(2)(B) of the Code.
PROPOSED RULES: Farmer and Fisherman Income Averaging,
Published: 2008-07-22
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing final and temporary regulations
under section 1301 of the Internal Revenue Code (Code) relating to the
averaging of farm and fishing income in computing income tax liability.
The regulations reflect changes to the law made by the American Jobs
Creation
PROPOSED RULES: Regulations Enabling Elections for Certain Transactions under Section 336(e); Correction,
Published: 2008-10-09
Correction
In proposed rule document E819603 beginning on page 49965 in
theissue of Monday, August 25, 2008, make the following correction: Sec. 1.3363 [Corrected]
1. On page 49979, in the first column, in Sec. 1.3363(d)(1), in
thetwentysecond line, ``into account in an amount'' should read``into account in amount''.
2. On the same
RULES: Consolidated Returns; Intercompany Obligations,
Published: 2008-12-29
This document contains final regulations under section 1502 of
the Internal Revenue Code (Code). The regulations provide guidance
regarding the treatment of transactions involving obligations between
members of a consolidated group. These final regulations will affect
affiliated groups of corporations filing consolidated returns.
PROPOSED RULES: Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable,
Published: 2008-04-23
This document withdraws a notice of proposed rulemaking
relating to the circumstances in which accounts or notes receivable are
``acquired * * * for services rendered'' within the meaning of section
1221(a)(4).
PROPOSED RULES: Hearing,
Published: 2008-03-06
This document provides notice of public hearing on proposed
regulations that would expand the list of permitted loan modifications
to include certain modifications of commercial mortgages.
PROPOSED RULES: Guidance for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions,
Published: 2008-06-24
In the Rules and Regulations section of this issue of the
Federal Register, the IRS and the Treasury Department are issuing
temporary regulations under section 956 of the Internal Revenue Code
(Code) relating to the determination of basis in property acquired by a
controlled foreign corporation in certain nonrecognition transactions
that are
PROPOSED RULES: Amendments to New Markets Tax Credit Regulations,
Published: 2008-08-11
This document contains proposed regulations relating to the
new markets tax credit under section 45D of the Internal Revenue Code
(Code). The proposed regulations revise and clarify certain rules
relating to recapture of the new markets tax credit and will affect
certain taxpayers claiming the new markets tax credit. This document
also provides a
RULES: Information Reporting on Employer-Owned Life Insurance Contracts,
Published: 2008-11-06
This document contains final regulations concerning
information reporting on employerowned life insurance contracts under
section 6039I of the Internal Revenue Code (Code). This final
regulation is necessary to provide taxpayers with guidance as to how
the requirements of section 6039I should be applied. These regulations
generally apply to
RULES: TIPRA Amendments to Section 199; Correction,
Published: 2008-03-28
This document contains a correction to final regulations (TD
9381) that were published in the Federal Register on Friday, February
15, 2008 (73 FR 8798) concerning the amendments made by the Tax
Increase Prevention and Reconciliation Act of 2005 to section 199 of
the Internal Revenue Code. These final regulations also contain a rule
concerning the
PROPOSED RULES: Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction,
Published: 2008-01-15
This document contains a correction to a notice of proposed
rulemaking by crossreference to temporary regulations and notice of
public hearing that was published in the Federal Register on Friday,
December 21, 2007 (72 FR 72645) providing guidance relating to the
reduction of the number of separate foreign tax credit limitation
categories under
PROPOSED RULES: Election to Expense Certain Refineries,
Published: 2008-07-09
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations relating to
the election to expense qualified refinery property under section 179C
of the Internal Revenue Code (Code) and affects taxpayers who own
refineries located in the United States. The temporary regulations
reflect changes
PROPOSED RULES: Targeted Populations Under Section 45D(e)(2),
Published: 2008-09-24
This document contains proposed regulations relating to how an
entity serving certain targeted populations under section 45D(e)(2) can
meet the requirements to be a qualified active lowincome community
business. The regulations reflect changes to the law made by the
American Jobs Creation Act of 2004. The regulations will affect certain
taxpayers
PROPOSED RULES: Determining the Amount of Taxes Paid for Purposes of Section 901; Hearing Cancellation,
Published: 2008-12-02
This document cancels a public hearing on proposed rulemaking
by crossreference to temporary regulations that provide guidance
relating to the determination of the purposes of the foreign tax
credits. The text of those temporary regulations also serves as the
text of these proposed regulations.
PROPOSED RULES: Dependent Child of Divorced or Separated Parents or Parents Who live Apart; Hearing,
Published: 2008-03-18
This document contains a notice of public hearing on proposed
regulations relating to a claim that a child is a dependent by parents
who are divorced, legally separated under a decree of separate
maintenance, agreement, or who live apart at all times during the last
6 months of the calendar year.
RULES: Treatment of Property Used to Acquire Parent Stock in Certain Triangular Reorganizations Involving Foreign Corporations,
Published: 2008-05-27
This document contains final and temporary regulations under
section 367(b) of the Internal Revenue Code (Code). The final
regulations revise an existing final regulation and add a cross
reference. The temporary regulations implement the rules described in
Notice 200685 and Notice 200748. The regulations affect corporations
engaged in certain
RULES: Dependent Child of Divorced or Separated Parents or Parents Who Live Apart; Correction,
Published: 2008-07-24
This document contains corrections to final regulations (TD
9408) that were published in the Federal Register on Wednesday, July 2,
2008 (73 FR 37797), relating to a claim that a child is a dependent by
parents who are divorced, legally separated under a decree of separate
maintenance, or separated under a written separation agreement, or who
live
PROPOSED RULES: to Participants of Consequences of Failing to Defer Receipt of Qualified Retirement Plan Distributions; Expansion of Applicable Election Period and Period f,
Published: 2008-10-09
This document contains proposed regulations under sections
402(f), 411(a)(11), and 417 of the Internal Revenue Code (Code). The
proposed regulations would provide that the notice required under
section 411(a)(11) to be provided to a participant of his or her right,
if any, to defer receipt of an immediately distributable benefit must
also describe
RULES: Guidance Regarding Foreign Base Company Sales Income,
Published: 2008-12-29
This document contains final and temporary regulations that
provide guidance relating to foreign base company sales income in cases
in which personal property sold by a controlled foreign corporation is manufactured,
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produced, or constructed pursuant to a contract manufacturing
arrangement or by one or more branches of the controlled
