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26. Withdrawal of Proposed Regulations Relating to Certain Corporate Reorganizations Involving Disregarded Entities;

PROPOSED RULES: Corporate reorganizations involving disregarded entities; withdrawn; Correction,

This document contains a correction to notice of proposed rulemaking (REG10618698) which was published in the Federal Register on Thursday, November 15, 2001 (66 FR 57400). This regulation relates to the withdrawal of proposed regulations relating to certain corporate reorganizations involving disregarded entities.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

27. Application of Section 904 to Income Subject to Separate Limitations and Section 864(e) Affiliated Group Expense

RULES: Income subject to separate limitations and affiliated group interest and other expense allocation and apportionment and foreign tax credit limitation; Correction,

This document contains corrections to final and temporary regulations that were published in the Federal Register on Wednesday, January 3, 2001 (66 FR 268) relating to the section 864(e)(5) and (6) rules on affiliated group interest and other expense allocation and other expense allocation and apportionment and to the section 904(d) foreign tax
DEPARTMENT OF THE TREASURY : Internal Revenue Service

28. Catch-Up Contributions for Individuals Age 50 or Over

PROPOSED RULES: Catch-up contributions for individuals age 50 or over,

This document contains proposed regulations that would provide guidance concerning the requirements for retirement plans providing catchup contributions to individuals age 50 or older pursuant to the provisions of section 414(v). These proposed regulations would affect section 401(k) plans, section 408(p) SIMPLE IRA plans, section 408(k)
DEPARTMENT OF THE TREASURY : Internal Revenue Service

29. Consolidated Returns; Applicability of Other Provisions of Law; Non-Applicability of Section 357(c)

PROPOSED RULES: Consolidated return regulations—; Non-applicability of section 357(c) in consolidated group,

This document proposes amendments relating to the consolidated return regulations dealing with the nonapplicability of section 357(c) in a consolidated group. The proposed amendments clarify that, in certain transfers described in section 351 between members of a consolidated group, a transferee's assumption of certain liabilities described in
DEPARTMENT OF THE TREASURY : Internal Revenue Service

30. Guidance on Filing an Application for a Tentative Carryback Adjustment in a Consolidated Return Context; Hearing

PROPOSED RULES: Tentative carryback adjustment in consolidated return context; filing application guidance; cross-reference; Hearing cancellation,

This document provides notice of cancellation of a public hearing on proposed regulations relating to the filing of application for a tentative carryback adjustment in a consolidated return context.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

31. Conforming Amendments to Section 446

PROPOSED RULES: Consolidated return regulations—; Intercompany transactions; timing rules,

On July 18, 1995, the Treasury and the IRS published final regulations governing the intercompany transaction system of the consolidated return regulations. Those regulations state that the timing rules of the intercompany transaction system are a method of accounting. At the time of the publication of those regulations, no amendment was made to
DEPARTMENT OF THE TREASURY : Internal Revenue Service

32. Guidance on Filing an Application for a Tentative Carryback Adjustment in a Consolidated Return Context

RULES: Tentative carryback adjustment in consolidated return context; filing application guidance,

This document contains final regulations relating to the filing of an application for a tentative carryback adjustment. These regulations provide guidance as to the time for filing such application by a consolidated group and by certain corporations for the separate return year created by their becoming a member of a consolidated group. These
DEPARTMENT OF THE TREASURY : Internal Revenue Service

33. Treaty Guidance Regarding Payments With Respect to Domestic Reverse Hybrid Entities; Correction

PROPOSED RULES: Domestic reverse hybrid entities; treaty guidance regarding payments; Correction,

This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on Tuesday, February 27, 2001 (66 FR 12445), relating to treaty guidance regarding payments with respect to domestic reverse hybrid entities.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

34. Prevention of Abuse of Charitable Remainder Trusts

RULES: Charitable remainder trusts; abuse prevention,

This document finalizes regulations that modify the application
[[Page 1035]]
of the rules governing the character of certain distributions from a charitable remainder trust. These regulations are necessary to prevent taxpayers from using charitable remainder trusts to achieve inappropriate tax avoidance. The regulations affect charitable
DEPARTMENT OF THE TREASURY : Internal Revenue Service

35. Effect of the Family and Medical Leave Act on the Operation of Cafeteria Plans; Correction

RULES: Cafeteria plans operation; effect of Family and Medical Leave Act; Correction,

This document contains corrections to final regulations that were published in the Federal Register on October 17, 2001 (66 FR 52675). These regulations relate to cafeteria plans that reflect changes made by the Family and Medical Leave Act of 1993 (Act).
DEPARTMENT OF THE TREASURY : Internal Revenue Service

36. Purchase Price Allocation in Deemed and Actual Asset Acquisitions; Correction

RULES: Purchase price allocations in deemed and actual asset acquisitions; Correction,

Correction

In rule document 017934 beginning on page 17362 in the issue of Friday, March 30, 2001, make the following correction:

On page 17363, in the table under the column heading ``Add'', in the second line, ``Sec. 1.338&2(c)(17)'' is corrected to read ``Sec. 1.3382(c)(17)''.
[FR Doc.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

37. Definition of Disqualified Person

PROPOSED RULES: Disqualified person; definition,

This document contains proposed regulations to narrow the definition of the term disqualified person for section 1031 likekind exchanges. The regulations are in response to recent changes in the federal banking law, especially the repeal of section 20 of the Glass Steagall Act of 1933. The regulations will affect the eligibility of certain persons
DEPARTMENT OF THE TREASURY : Internal Revenue Service

38. Treaty Guidance Regarding Payments With Respect to Domestic Reverse Hybrid Entities

PROPOSED RULES: Domestic reverse hybrid entities; treaty guidance regarding payments,

This document contains proposed regulations under section 894 of the Internal Revenue Code relating to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. law but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (a domestic
DEPARTMENT OF THE TREASURY : Internal Revenue Service

39. Guidance under section 355(e); Recognition of Gain on Certain Distributions of Stock or Securities In Connection with

PROPOSED RULES: Controlled corporations; recognition of gain on certain distributions of stockor securities in connection with acquisition,

This document contains proposed regulations relating to recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition. Changes to the applicable law were made by the Taxpayer Relief Act of 1997. These proposed regulations affect corporations and are necessary to provide them with
DEPARTMENT OF THE TREASURY : Internal Revenue Service

40. Minimum Cost Requirement Permitting the Transfer of Excess Assets of a Defined Benefit Pension Plan to a Retiree

RULES: Defined benefit pension plan; excess assets transfer to retiree health account; minimum cost requirement,

This document contains final Income Tax Regulations relating to the minimum cost requirement under section 420, which permits the transfer of excess assets of a defined benefit pension plan to a retiree health account. Pursuant to section 420(c)(3)(E), these regulations provide that an employer who significantly reduces retiree health coverage
DEPARTMENT OF THE TREASURY : Internal Revenue Service

41. Source of Income From Certain Space and Ocean Activities; Also, Source of Communications Income; Hearing

PROPOSED RULES: Space and ocean activities and communication; source of income; Hearing date change,

This document changes the date of the public hearing on the proposed regulations under sections 863(a)(d) and (e) governing the source of income from certain communications activities. It also extends the time to submit outlines of oral comments for the hearing.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

42. Section 467 Rental Agreements Involving Payments of $2,000,000 or Less

RULES: Section 467 rental agreements involving payments of $2,000,000 or less,

This document contains final regulations concerning section 467 rental agreements. The regulations provide amendments to the regulations under section 467, including the removal of the exception to constant rental accrual for rental agreements involving payments of $2,000,000 or less. The regulations affect taxpayers that are parties to a section
DEPARTMENT OF THE TREASURY : Internal Revenue Service

43. Constructive Transfers and Transfers of Property to a Third Party on Behalf of a Spouse; Hearing Cancellation

PROPOSED RULES: Constructive and property transfers to third party on behalf of spouse; Hearing cancelled,

This document provides notice of cancellation of a public hearing on proposed regulations relating to the tax treatment of certain redemptions, during marriage or incident to divorce, of stock owned by a spouse or former spouse.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

44. New Markets Tax Credit

Part IV: Department of the Treasury, Internal Revenue Service, and Community Development Financial Institutions Fund,

This document invites comments from the public on issues that the IRS may address in regulations relating to the new markets tax credit under section 45D. A taxpayer that makes a qualified equity investment in a qualified community development entity that has received a new markets tax credit allocation may claim a 5percent credit for each of the
DEPARTMENT OF THE TREASURY : Veterans Affairs Department

45. Taxable Years of Partner and Partnership; Foreign Partners

PROPOSED RULES: Partnerships with foreign partners; taxable years,

This document contains proposed regulations on the taxable year of a partnership with foreign partners. The proposed regulations affect partnerships and their partners. This document also contains a notice of public hearing on these proposed regulations.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

46. Determination of Basis of Partner's Interest; Special Rules; Correction

PROPOSED RULES: Partner's interest basis determination under section 705; special rules; Correction,

This document contains corrections to REG-106702-00 which [[Page 12449]]
was published in the Federal Register on Wednesday, January 3, 2001 (66 FR 315). These regulations relate to special rules on determination of basis of partner's interest under section 705 of the Internal Revenue Code.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

47. Definition of Hyperinflationary Currency for Purposes of Section 988

RULES: Hyperinflationary currency; definition,

This document contains final regulations concerning when a currency will be considered hyperinflationary for purposes of section 988. These final regulations are intended to prevent distortions associated with the computation of income and expense arising from section 988 transactions denominated in hyperinflationary currencies.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

48. Special Aggregate Stock Ownership Rules

RULES: Special aggregate stock ownership rules,

This document contains final regulations relating to the aggregation of stock ownership in a corporation of members of a consolidated group. These regulations reflect a technical correction enacted in section 311(c) of the Community Renewal Tax Relief Act of 2000, that, in substance, provides that the special aggregate stock ownership rules shall
DEPARTMENT OF THE TREASURY : Internal Revenue Service

49. Stock Transfer Rules: Carryover of Earnings and Taxes

PROPOSED RULES: Stock transfer rules—; Earnings and taxes carryover; correction,

Correction

In proposed rule document 0028950 beginning on page 69138 in the issue of Wednesday, November 15, 2000, make the following corrections: Sec. 1.367(b)7 [Corrected]

1. On page 69158, in Sec. 1.367(b)7(e)(2)(iv), Example 2(i) Facts., in the first table, in the column titled ``E&P'', ``(200u)'' should read ``200u''.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

50. Minimum Cost Requirement Permitting the Transfer of Excess Assets of a Defined Benefit Pension Plan to a Retiree

PROPOSED RULES: Defined benefit pension plan; excess assets transfer to retiree health account; minimum cost requirement; hearing,

This document contains proposed Income Tax Regulations relating to the minimum cost requirement under section 420, which permits the transfer of excess assets of a defined benefit pension plan to a retiree health account. Pursuant to section 420(c)(3)(E), these proposed regulations provide that an employer who significantly reduces retiree health
DEPARTMENT OF THE TREASURY : Internal Revenue Service

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