This document contains final 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.
This document contains corrections to final regulations that were published in the Federal Register on March 18, 2005 (70 FR 13100) 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.
This document contains a correction to a notice of proposed rulemaking and notice of public hearing that was published in the Federal Register on Friday, August 12, 2005 (70 FR 47155) relating to the anticutback rules under section 411(d)(6) of the Internal Revenue Code.
This document contains temporary regulations under section 7874 of the Internal Revenue Code (Code) relating to the disregard of certain affiliateowned stock in determining whether a corporation is a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of the temporary regulations also serves as the text of the proposed
This document corrects final regulations and removal of temporary regulations (TD 9198), that were published in the Federal Register on Tuesday, April 19, 2005 (70 FR 20279) that relate to the recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition.
This document contains final 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pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and
This document provides cancellation of a public hearing for proposed regulations that 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
This document contains final 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
This document contains proposed regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in
This document contains a correction to final regulations that were published in the Federal Register on July 12, 2005 (70 FR 39920) regarding the LIFO recapture by corporations converting from C Corporations to S Corporations.Years: 20002001200220032004200520062007200820092010201120122013