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PROPOSED RULES: National principal contracts; contingent nonperiodic payments; Hearing cancelled,
Published: 2004-05-14
This document cancels a public hearing on a notice of proposed
rulemaking under section 446(b) of the Internal Revenue Code relating
to the inclusion into income or deduction of a contingent nonperiodic
payment provided for under a notional principal contract (NPC).
PROPOSED RULES: Controlled foreign corporations’ subpart F income; U.S. shareholder's pro rata share; determination guidance,
Published: 2004-08-06
This document contains proposed regulations under section
951(a) of the Internal Revenue Code (Code) that provide guidance for
determining a United States shareholder's pro rata share of a
controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from
[[Page 47823]]
investment in less developed
PROPOSED RULES: Controlled foreign corporations’ subpart F income; U.S. shareholder's pro rata share; determination guidance; correction,
Published: 2004-09-28
This document contains corrections to notice of proposed
rulemaking that were published in the Federal Register on August 6,
2004 (69 FR 47822) providing guidance for determining a United States
shareholder's pro rata share of a controlled foreign corporation's
(CFC's) subpart F income, previously excluded subpart F income
withdrawn from
PROPOSED RULES: Mortgage revenue bonds; public hearing; cancelled,
Published: 2004-01-21
This document provides notice of cancellation of a public
hearing on proposed regulations that provide guidance regarding the
limitation on the effective rate of mortgage interest for purposes of
mortgage revenue bonds issued by State and local governments.
PROPOSED RULES: Computing depreciation changes; hearing cancellation,
Published: 2004-03-30
This document cancels a public hearing on a notice of proposed
rulemaking 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 (or vice versa).
RULES: Depreciation of vans and light trucks,
Published: 2004-06-25
This document contains regulations relating to the definition
of passenger automobile for purposes of the dollar limits on
depreciation deductions for passenger automobiles. These regulations
affect certain taxpayers that use vans and light trucks in their trade
or business.
RULES: Tax-exempt bonds issued by State and local governments; remedial actions,
Published: 2004-08-13
This document contains final regulations on the exempt
facility bond rules applicable to taxexempt bonds issued by state and
local governments. The regulations affect issuers of taxexempt bonds
and amend provisions in the current regulations permitting remedial
actions for taxexempt bonds issued by state and local governments.
PROPOSED RULES: Charitable contributions, allocation and apportionment of deductions; hearing cancellation,
Published: 2004-11-23
This document provides notice of cancellation of a public
hearing on proposed regulations relating to the allocation and
apportionment of charitable deductions.
RULES: Low-income housing tax credit; section 42 carryover and stacking rule amendments; Correction,
Published: 2004-02-24
This document contains corrections to final regulations that
were published in the Federal Register on January 6, 2004 (69 FR 502)
that amend several existing regulations concerning the lowincome housing tax credit.
[[Page 8331]]
PROPOSED RULES: Stock or securities in exchange for, or with respect to, stock or securities in certain transactions; determination of basis,
Published: 2004-05-03
This document contains proposed regulations under section 358
that provide guidance regarding the determination of the basis of stock
or securities received in exchange for, or with respect to, stock or
securities in certain transactions. These proposed regulations affect
shareholders of corporations.
PROPOSED RULES: Income subject to separate limitations and deemed-paid credit computation,
Published: 2004-07-20
This document withdraws a portion of a notice of proposed
rulemaking published on January 3, 2001, relating to the application of
the foreign tax credit limitation under section 904 and the deemedpaid
credit under section 902.
PROPOSED RULES: Real estate mortgage investment conduits—; Interest-only regular interest,
Published: 2004-08-25
This document describes and explains rules that the IRS and
Treasury are considering and may propose in a notice of proposed
rulemaking regarding the proper timing of income or deduction
attributable to an interestonly regular interest in a Real Estate
Mortgage Investment Conduit (REMIC). This document also invites
comments from the public
PROPOSED RULES: Pension plan distributions under a phased retirement program; correction,
Published: 2004-12-28
This document contains a notice of public hearing on a
proposed rulemaking that provide 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.
PROPOSED RULES: Employees of 501(c)(3) organizations in 401(k) and 401(m) plans; exclusion,
Published: 2004-03-16
This document contains proposed amendments to the regulations
under section 410(b) of the Internal Revenue Code. The proposed
amendments permit, in certain circumstances, employees of a taxexempt
organization described in section 501(c)(3) to be excluded for the
purpose of testing whether a section 401(k) plan (or a section 401(m)
plan that is
RULES: Safe harbor sale and leaseback transactions; uniform capitalization of interest expense,
Published: 2004-05-20
This document contains regulations relating to the
capitalization of interest expense incurred in sale and leaseback
transactions under the Economic Recovery Tax Act of 1981 (ERTA) safe
harbor leasing provisions. The regulations affect taxpayers that
provide purchase money obligations in connection with these
transactions. The text of the
PROPOSED RULES: Labor and personal services; source of compensation,
Published: 2004-08-06
This document contains new proposed rules that describe the
proper basis for determining the source of compensation from labor or
personal services performed partly within and partly without the United
States. The new proposed rules will affect individuals that earn
compensation from labor or personal services performed partly within
and partly
PROPOSED RULES: Controlled foreign corporations’ subpart F income; U.S. shareholder's pro rata share; determination guidance; Correction,
Published: 2004-10-01
This document contains corrections to notice of proposed
rulemaking that were published in the Federal Register on August 6,
2004 (69 FR 47822), providing guidance for determining a United States
shareholder's pro rata share of a controlled foreign corporation's
(CFC's) subpart F income, previously excluded subpart F income
withdrawn from
RULES: Low-income housing tax credit allocation certification; electronic filing,
Published: 2004-01-27
This document contains regulations that facilitate the
electronic filing of Form 8609, ``LowIncome Housing Credit Allocation
Certification.'' The regulations affect taxpayers who file Form 8609.
PROPOSED RULES: Modified accelerated cost recovery system property; changes in use; depreciation; correction,
Published: 2004-03-30
This document corrects a notice of proposed rulemaking; notice
of proposed rulemaking by crossreference to temporary regulations;
notice of public hearing; and partial withdrawal of proposed
regulations (REG10659000, REG13849902) that were published in the
Federal Register on Monday, March 1, 2004 (69 FR 9560) relating to the
depreciation of
PROPOSED RULES: Adjustment to net unrealized built-in gain,
Published: 2004-06-25
This document contains proposed regulations under section 1374
that provide for an adjustment to the amount that may be subject to tax
under section 1374 in certain cases in which an S corporation acquires
assets from a C corporation in an acquisition to which section
1374(d)(8) applies. These proposed regulations provide guidance to
certain S
PROPOSED RULES: C corporations converting to S corporations; LIFO recapture,
Published: 2004-08-13
This document contains proposed regulations regarding LIFO
recapture by corporations converting from C corporations to S
corporations. The purpose of the proposed regulations is to provide
guidance on the LIFO recapture requirement when the corporation holds
inventory accounted for under the lastin, firstout (``LIFO'') method
(LIFO inventory)
PROPOSED RULES: Timely mailing of documents and payments treated as timely filing and paying; Public hearing,
Published: 2004-11-24
This document contains a notice of public hearing on proposed
regulations that would amend Sec. 301.75021(e) to provide that, other
than direct proof of actual delivery, a registered or certified mail
receipt is the only prima facie evidence of delivery of documents that
have a filing deadline prescribed by the internal revenue laws.
PROPOSED RULES: Charitable remainder trusts; ordering rule application; hearing cancellation,
Published: 2004-02-26
This document provides notice of cancellation of a public [[Page 8886]]
hearing on the ordering of rules of section 664(b) for characterizing
distributions from charitable remainder trusts.
RULES: Consolidated return regulations—; Loss limitation rules; correction,
Published: 2004-05-06
This document contains corrections to TD 9118, which was
published in the Federal Register on Thursday, March 18, 2004 (69 FR
12799), 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
PROPOSED RULES: Optional 10-year writeoff of certain tax preferences,
Published: 2004-07-20
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