In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under sections 446(e) and 1016(a)(2) of the Internal Revenue Code relating to a change in computing depreciation or amortization as well as a change from a nondepreciable or nonamortizable asset to a depreciable or amortizable asset

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations providing an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of Sec. 1.8619T. The alternative tax book value method, which is elective, allows taxpayers to determine, for purposes of apportioning expenses, the tax book value of all tangible

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations relating to the depreciation of property subject to section 168 of the Internal Revenue Code (MACRS property). Specifically, these regulations provide guidance on how to depreciate MACRS property for which the use changes in the hands of the same taxpayer. The regulations reflect changes to

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance regarding the requirements for a transaction to qualify as a reorganization under section 368(a)(1)(E) or (F) of the Internal Revenue Code. The proposed regulations will affect corporations and their shareholders.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of cancellation of public hearing relating to the election to expense the cost of property subject to section 179.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a withdrawal of previous proposed rules; notice of proposed rulemaking by crossreference to temporary regulations and notice of public hearing that was published in the Federal Register on Tuesday, December 30, 2003 (68 FR 75182), relating to information reporting by a corporation if control of the corporation

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a notice of proposed rulemaking (REG- [[Page 22464]]
10668102) that was published in the Federal Register on Thursday, April 1, 2004 (69 FR 17117) that clarifies that qualified REIT subsidiaries, qualified subchapter S subsidiaries, and single owner eligible entities that are disregarded as entities separate from their owners

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of cancellation of a public hearing on proposed rulemaking that clarify that qualified REIT subsidiaries, qualified subchapter S subsidiaries, and single owner eligible entities that are disregarded as entities separate from their owners are treated as separate entities for purposes of any Federal tax liability for

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance regarding the effect of certain transfers of assets or stock on the qualification of certain transactions as reorganizations under section 368(a). This document also contains proposed regulations that provide guidance on the continuity of business enterprise requirement and the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

These temporary regulations provide guidance concerning the applicability of section 1374 to S corporations that acquire assets in carryover basis transactions from C corporations on or after December 27, 1994, and to certain corporations that terminate S corporation status and later elect again to become S corporations. The text of the temporary

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing revised temporary regulations relating to the new markets tax credit. The text of those regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations regarding the reduction of tax attributes under sections 108 and 1017 of the Internal Revenue Code. These final regulations affect taxpayers that realize income from the discharge of indebtedness that is excluded from gross income pursuant to section 108.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations relating to an election that may be made by noncorporate taxpayers to treat qualified dividend income as investment income for purposes of calculating the deduction for investment interest. The regulations reflect changes to the law made by the Jobs and Growth Tax Relief Reconciliation Act of 2003. The

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations relating to the allocation of purchase price in certain deemed and actual asset acquisitions under sections 338 and 1060. These regulations affect sellers and purchasers of nuclear power plants or of the stock of corporations that own nuclear power plants. The text of the temporary regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document invites comments from the public regarding certain rules and standards relating to internaluse software under section 41(d)(4)(E) of the Internal Revenue Code. All materials submitted will be available for public inspection and copying. This document also addresses the effective date for final rules relating to internaluse software.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations providing an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of Sec. 1.8619T. The alternative tax book value method, which is elective, allows taxpayers to determine, for

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to a correction notice for proposed regulations that were published in the Federal Register on March 23, 2004 (69 FR 13498) relating to the inclusion into income or deduction of a contingent nonperiodic payment provided for under a notional principal contract (NPC).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9140), which was published in the Federal Register on July 20, 2004 (69 FR 43302). The document contains final regulations relating to transfers of money or other property to provide for the satisfaction of contested liabilities.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that define the terms predecessor and successor for purposes of section 355(e). These proposed regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation, as well as rules to assist taxpayers in determining whether an

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed amendments to the regulations under section 402(a) of the Internal Revenue Code regarding the amount includible in a distributee's income when life insurance contracts are distributed by a qualified retirement plan and the treatment of property sold by a qualified retirement plan to a plan participant or beneficiary

DEPARTMENT OF THE TREASURY : Internal Revenue Service

These regulations finalize the rules relating to the treatment, for purposes of the atrisk limitations, of amounts borrowed from a person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest. These regulations affect taxpayers subject to the atrisk

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to transfers of money or other property to provide for the satisfaction of contested liabilities. The regulations affect taxpayers that are contesting an asserted liability and that transfer their own stock or indebtedness, the stock or indebtedness of a related party, or a promise to provide

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations providing guidance regarding the treatment of certain losses available to acquired subsidiaries as a result of an election made under the section 1502 regulations. The text of these proposed regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance concerning the applicability of section 1374 to S corporations that acquire assets in carryover basis transactions from C corporations on or after December 27, 1994, and to certain corporations that terminate S

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations under section 1502 that govern the application of section 108 when a member of a consolidated group realizes discharge of indebtedness income. These regulations affect corporations filing consolidated returns.

DEPARTMENT OF THE TREASURY : Internal Revenue Service