This document contains proposed regulations relating to the optional 10year writeoff of certain tax preference items under section 59(e) of the Internal Revenue Code (Code). These proposed regulations provide guidance on the time and manner of making an election under section 59(e). The regulations also provide guidance on revoking an election

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations relating to the accrual of original issue discount (OID) on certain real estate mortgage investment conduit (REMIC) regular interests. The proposed regulations are necessary to provide guidance to REMICs, REMIC regular interest holders and information reporters regarding the accrual of OID. This document

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking that was published in the Federal Register on November 10, 2004 (69 FR 65108), providing rules permitting distributions to be made from a pension plan under a phased retirement program and set forth requirements for a bona fide phased retirement program.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains amendments relating to certain aspects of the temporary regulations addressing the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group and to the consequences of treating subsidiary stock as worthless. In addition, this document contains temporary regulations that clarify

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing final and temporary regulations relating to the capitalization of interest expense in sale and leaseback transactions under the Economic Recovery Tax Act of 1981 (ERTA) safe harbor leasing provisions. The regulations affect taxpayers that provide

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains regulations that provide rules governing transfers of certain compensatory stock options (nonstatutory stock options). The regulations affect persons who have been granted nonstatutory stock options, as well as service recipients who may be entitled to deductions related to the options.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In rule document 0419478 beginning on page 55743 in the issue of Thursday, September 16, 2004, make the following corrections:

1. On page 55743, in the second column, in the first full paragraph, in the tenth line, ``sect;1.60911(b)'' should read ``Sec. 1.60911(b).''

Sec. 1.60912 [Corrected]

2. On page 55744, in the second

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In rule document 0331900 beginning on page 75128 in the issue of Tuesday, December 30, 2003, make the following correction:

Sec. 1.60114 [Corrected]

On page 75130, in Sec. 1.60114, in the second column, after paragraph (b)(3)(v), add
``* * * * *''
to the end of the paragraph.
[FR Doc. C331900 Filed 12904; 8:45 am]
BILLING CODE

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In proposed rule document 044483 beginning on page 9771 in the issue of Tuesday, March 2, 2004 make the following corrections: Sec. 1.3681 [Corrected]

1. On page 9773, in the third column, in Sec. 1.3681, in paragraph (d)(4)(i)(B), in the second line, ``or'' should read ``aquired, or''.

2. On the same page, in the same column,

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a proposed regulation relating to the determination of income of foreign insurance companies that is effectively connected with the conduct of a trade or business within the United States. The regulation provides that the exception to the assetuse test for stock shall not apply in determining whether the income, gain, or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance regarding the treatment of manufacturer incentive payments between members of a consolidated group. The proposed regulations are necessary to provide additional guidance for a variety of transactions involving manufacturer incentive payments. The regulations will affect corporations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations relating to the treatment of transactions between a partnership and its partners as disguised sales of partnership interests between the partners under section 707(a)(2)(B) of the Internal Revenue Code (Code). The proposed regulations affect partnerships and their partners, and are necessary to provide

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations relating to the inclusion into income or deduction of a contingent nonperiodic payment provided for under a notional principal contract (NPC). This document also provides guidance relating to the character of payments made pursuant to an NPC. These regulations will affect taxpayers that enter into NPCs.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to the capital account maintenance rules under section 704 of the Internal Revenue Code. These regulations expand the rules regarding a partnership's right to adjust capital accounts to reflect unrealized appreciation and depreciation in the value of partnership assets.

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 relating to qualification of governmental units as qualified nonbank trustees for deemed IRAs under section 408(q). The text of those regulations also serves as the text of these proposed regulations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations under section 1502 of the Internal Revenue Code of 1986. The temporary regulations extend the time for consolidated groups to elect to apply a method for determining allowable loss on a disposition of subsidiary stock, and permit consolidated groups to revoke such elections. The temporary 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 under sections 337(d) and 1502 of the Internal Revenue Code relating to the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group, the consequences of treating subsidiary stock as

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of cancellation of a public hearing on regulations providing that a Form 5472 that is timely filed electronically is treated as satisfying the requirement timely to file a duplicate Form 5472 with the Internal Revenue Service Center in Philadelphia, Pennsylvania.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance regarding the satisfaction of the continuity of interest requirement for corporate reorganizations. These proposed regulations affect corporations and their shareholders. This document also provides a notice of a public hearing on these proposed regulations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations that were published in the Federal Register on July 20, 2004 (69 FR 43304). This regulation relates to the section 904(d) foreign tax credit limitation and to the exclusion of certain export financing interest from foreign personal holding company income.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In rule document 0331238 beginning on page 70701 in the issue of Friday, December 19, 2003, make the following corrections:

1. On page 70703, in the first column, under the heading ``5. Form 1120: U.S. Corporation Income Tax Return'', in the first paragraph, in the 20th line from the bottom, ``(g)(2)(iv)(B)(3)(iii)'' should read

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final and temporary regulations that were published in the Federal Register on Monday, March 1, 2004 (69 FR 9529) relating to the depreciation of property subject to section 168 of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to the inclusion in gross income of advance rentals. The regulations authorize the Commissioner to provide rules allowing for the inclusion of advance rentals in gross income in a year other than the year of receipt. The regulations will affect taxpayers that receive advance payments for the use of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing final and temporary regulations replacing the use of the Standard Industrial Classification (SIC) system with the North American Industry Classification System (NAICS) for determining what properties are of a like class for purposes of section 1031 of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of a public hearing for proposed regulations provide rules under section 752 for taking into account certain obligations of a business entity that is disregarded as separate from its owner under section 856(i), 1361(b)(3), or Sec. Sec. 301.77011 through 301.77013 (disregarded entity) for purposes of charactering and

DEPARTMENT OF THE TREASURY : Internal Revenue Service