This document contains proposed regulations relating to the application of the unified partnership audit procedures to disputes regarding the ownership of residual interests in a Real Estate Mortgage Investment Conduit (REMIC). These regulations will affect taxpayers that invest in REMIC residual interests.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a notice of public hearing on proposed regulations relating to the optional 10year writeoff of certain tax preference items under section 59(e).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to TD 9088, which was published in the Federal Register on August 26, 2003 (68 FR 51171) that provide guidance regarding the application of the rules of section 482 governing qualified cost sharing arrangements.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to an advance notice of proposed rulemaking that was published in the Federal Register on Friday, May 7, 2004 (69 FR 25534), soliciting comments and suggestions regarding the scope and details of regulations that may be proposed under section 7701(f) of the Internal Revenue Code to address the application of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to partnership transactions involving contracts accounted for under a longterm contract method of accounting. The regulations are necessary to resolve issues that were reserved in final regulations under section 460 that were published in the Federal Register on May 15, 2002, addressing other

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document withdraws a notice of proposed rulemaking regarding the effect of certain transfers of assets or stock on the qualification of certain transactions as reorganizations under section 368(a). The proposed regulations were published on March 2, 2004. After consideration of additional issues related to the effect of transfers of assets or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations concerning requirements for employee stock ownership plans (ESOPs) holding stock of Subchapter S corporations. The temporary regulations provide guidance on the definition and effects of a prohibited allocation under section 409(p), identification of disqualified persons and determination of a

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking (REG10633002) that was published in the Federal Register on Monday, November 24, 2003 (68 FR 65864). These proposed regulations relate to the tax treatment of installment obligations and property acquired pursuant to a contract under sections 704(c) and 737.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

The temporary regulations provide rules for the proper allocation of partnership expenditures for foreign taxes. The temporary regulations affect partnerships and their partners. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations relating to the allocation and apportionment of the deduction for charitable contributions allowed by sections 170, 873(b)(2), and 882(c)(1)(B). These regulations change the method of allocating and apportioning these deductions from ratable apportionment on the basis of gross income to apportionment on

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document changes the date of the public hearing on the notice of proposed rulemaking that relates to the application of section 1045 of the Internal Revenue Code (Code) to partnerships and their partners. It also extends the time to submit outlines of oral comments for the hearing.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

The IRS and Treasury Department are soliciting comments and suggestions regarding the scope and details of regulations that may be proposed under section 7701(f) of the Internal Revenue Code to address the application of sections 265(a)(2) and 246A in transactions involving related parties, passthrough entities, or other
intermediaries.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

The 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 sections 856(i), 1361(b)(3), or Sec. Sec. 301.77011 through 301.77013 (disregarded entity) for purposes of characterizing and allocating partnership liabilities. The rules

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This notice of proposed rulemaking contains proposed amendments to the Income Tax Regulations under section 401(a) of the Internal Revenue Code. These proposed regulations 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. The

DEPARTMENT OF TREASURY : Internal Revenue Service

This document contains corrections to proposed regulations that were published in the Federal Register on February 26, 2004 (69 FR 8886) that relate 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 final regulations concerning required minimum distributions under section 401(a)(9) for defined benefit plans and annuity contracts providing benefits under qualified plans, individual retirement plans, and section 403(b) contracts. This document also contains a change to the separate account rules in the final regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document removes a temporary regulation that provides a rule for an election to deduct vested accrued vacation pay for the first taxable year ending after July 18, 1984. The repeal of the underlying code section in 1987 has rendered the temporary regulation obsolete. The removal of this regulation will not affect taxpayers.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a withdrawal of notice of proposed rulemaking and notice of proposed rulemaking (REG20825490 and REG 13648104) that was published in the Federal Register on Friday, August 6, 2004 (69 FR 47816), that contains new proposed rules that describe the proper basis for determining the source of compensation from labor or personal

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 on the definition and effects of a prohibited allocation under section 409(p), identification of disqualified persons and determination of a nonallocation year, calculation of synthetic equity under section

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary 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. This action is necessary to clarify how the duplicate filing requirements for

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations relating to the proper allocation of partnership expenditures for foreign taxes. The proposed regulations affect partnerships and their partners. In the rules and regulations portion of this issue of the Federal Register, the IRS is issuing temporary regulations that modify the rules relating to the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document withdraws the notice of proposed rulemaking published on March 12, 1991 (the 1991 proposed regulations), relating to the allocation and apportionment of charitable deductions. In addition, in the Rules and Regulations section of this issue of the Federal Register, the Treasury Department and the IRS are issuing temporary regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9137) that were published in the Federal Register on Friday, July 16, 2004 (69 FR 42551) relating to partnership transactions involving contracts accounted for under a longterm contract method of accounting.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains amendments to temporary regulations for the new markets tax credit under section 45D. The regulations revise and clarify certain aspects of those regulations and affect a taxpayer making a qualified equity investment in a qualified community development entity that has received a new markets tax credit allocation. The text

DEPARTMENT OF THE TREASURY : Internal Revenue Service