This document contains proposed regulations providing guidance regarding corporate formations, reorganizations, and liquidations of insolvent corporations. These regulations provide rules requiring the exchange (or, in the case of section 332, a distribution) of net value for the nonrecognition rules of subchapter C to apply to the transaction.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations regarding the application of section 409A to nonqualified deferred compensation plans. The regulations affect service providers receiving amounts of deferred compensation, and the service recipients for whom the service providers provide services. This document also provides a notice of public hearing on

DEPARTMENT OF THE TREASURY : Treasury Department

This document contains temporary regulations under section 408A of the Internal Revenue Code (Code). These temporary regulations provide guidance concerning the tax consequences of converting a non Roth IRA annuity to a Roth IRA. These temporary regulations affect individuals establishing Roth IRAs, beneficiaries under Roth IRAs, and trustees,

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that would revise final regulations that were issued on
[[Page 4059]]
December 17, 2003, under section 417(a)(3) of the Internal Revenue Code concerning content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable under

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under sections 704(c) and 737 relating to the tax treatment of installment obligations and property acquired pursuant to a contract. The regulations affect partners and partnerships and provide guidance necessary to comply with the law.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed amendments to the regulations under section 367 relating to certain transfers of stock involving foreign corporations in transactions governed by section 304. Specifically, these proposed regulations provide that if, pursuant to section 304(a)(1), a U.S person is treated as transferring stock of a domestic or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document adds the text that was inadvertently omitted from the Code of Federal Regulations. The text was originally published in TD 9193, which was published in the Federal Register on Friday, March 22, 2005 (70 FR 14394). The final regulations relate to the tax treatment of installment obligations and property acquired pursuant to a

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed amendments to the regulations under section 401(k) and (m) of the Internal Revenue Code. These [[Page 10063]]
proposed regulations would provide guidance concerning the requirements for designated Roth contributions to qualified cash or deferred arrangements under section 401(k). These proposed regulations would

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 355(e) of the Internal Revenue Code relating to the 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 regulations affect

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document cancels a public hearing on proposed regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In rule document 053951 beginning on page 10319 in the issue of Thursday, March 3, 2005, make the following corrections:

Sec. 1.150220 [Corrected]

1. On page 10323, in Sec. 1.150220, in the first column, in paragraph (i)(3)(iii)(D)(1), in the first line, ``(1) Limitations'' should read ``(1) Limitations''.

2. On the same

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects the notice of proposed rulemaking (REG- 10603098) that was published in the Federal Register on Monday, September 19, 2005 (70 FR 54859) under section 863(d) governing the source of income from certain space and ocean activities.

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 section 408A of the Internal Revenue Code (Code). The temporary regulations provide guidance concerning the tax consequences of converting a nonRoth IRA annuity to a Roth IRA. The temporary regulations affect individuals

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects temporary regulations (TD 9170) that were published in the Federal Register on Wednesday, December 22, 2004 (69 FR 76612), 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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In rule document 0427294 beginning on page 75455 in the issue of Friday, December 17, 2004, make the following corrections:

Sec. 1.409(p)1T [Corrected]

1. On page 75462, in Sec. 1.409(p)1T(c)(3)(ii), in the first column, in the fifth line, ``(d)(2)(ii)(b)'' should read

``(d)(2)(ii)(b)''.

2. On page 75466, in the same

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 assumption of liabilities under section 752 of the Internal Revenue Code (Code). Those temporary regulations contain rules related to the assumption of certain liabilities under section 358(h). The text of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations relating to the capitalization of costs under the simplified service cost method of the Income Tax Regulations and the simplified production method. The regulations affect taxpayers that use the simplified service cost method or the simplified production method for self constructed assets that

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 the definition of qualified amended returns. The text of those regulations also serves as the text of these proposed regulations.

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 Thursday, March 10, 2005 (70 FR 11903). The proposed regulation provides guidance regarding corporate formations, reorganizations, and liquidations of insolvent corporations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to temporary regulations (TD 9186) which were published in the Federal Register on Wednesday, March 2, 2005 (70 FR 10037). The temporary regulations modify the rules relating to qualified amended returns by providing additional circumstances that end the period within which a taxpayer may file an amended return

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations that provide guidance concerning the applicability of section 1374 of the Internal Revenue Code 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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final 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. These regulations provide guidance to State and local governments that issue taxexempt mortgage revenue bonds.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final regulations (TD 9207) that were published in the Federal Register on Thursday, May 26, 2005 (70 FR 30334).
[[Page 39654]]
The final regulation relates to the definition of liabilities under section 752 of the Internal Revenue Code.

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 December 17, 2004 (69 FR 75492), relating to prohibited allocations of securities in an S Corporation.

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 certain elections for taxpayers, who in limited circumstances, continue to be subject to the excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as

DEPARTMENT OF THE TREASURY : Internal Revenue Service