In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the disregard of affiliateowned stock in determining the percentage of stock of a foreign corporation held by former shareholders or partners of a domestic entity, in order to determine whether the foreign corporation is

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of cancellation of a public hearing on proposed rulemaking that affects corporations engaging in mergers
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and consolidations and their shareholders under sections 358, 368(a)(1)(A), 367 and 884 of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final regulation (TD 9207) that were published in the Federal Register on Thursday, May 26, 2005 (70 FR 30334). 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 proposed regulations amending the income tax regulations under various provisions of the Internal Revenue Code (Code) to account for statutory mergers and consolidations under section 368(a)(1)(A) (including reorganizations described in section 368(a)(2)(D) and (E)) involving one or more foreign corporations. These proposed

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 Tuesday, October 4, 2005 (70 FR 57930) regarding the application of section 409A to nonqualified deferred compensation plans. The regulations affect service providers receiving amounts of deferred compensation, and the service

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 computation and allocation of the credit for increasing research activities for members of a controlled group of corporations, including consolidated groups, or a group of trades or businesses under common control.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects temporary regulations (TD 9205) that were published in the Federal Register on Tuesday, May 24, 2005 (70 FR 29596). The document contains temporary regulations relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to the application of the unified partnership audit
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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 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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

DEPARTMENT OF THE TREASURY : Western Area Power Administration

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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations regarding reorganizations under section 368(a)(1)(E) and section 368(a)(1)(F) of the Internal Revenue Code. The regulations affect corporations and their shareholders.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final regulations, (TD 9192) that were published in the Federal Register on Tuesday, March 22, 2005 (70 FR 14395), that govern the application of section 108 when a member of a consolidated group realizes discharge of indebtedness income.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations, including consolidated groups, or a group of trades or businesses under common control.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In proposed rule document 0519379 beginning on page 57930 in the issue of Tuesday, October 4, 2005, make the following corrections:

1. On page 57933, in the first column, under the heading C. Stock Options and Stock Appreciation Rights, the secondary heading ``In General'' should read ``1. In General ''.

2. On the same page, in

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations that replace 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 the Internal Revenue Code (Code). The regulations affect taxpayers that engage in

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations under sections 162(k) and 404(k) of the Internal Revenue Code (Code) relating to employee stock ownership plans (ESOPs). The regulations provide guidance concerning which corporation is entitled to the deduction for applicable dividends under section 404(k). These regulations also clarify that a payment

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations that would modify the circumstances under which certain forms of distribution previously available are permitted to be eliminated from qualified defined contribution plans. These final regulations affect qualified retirement plan sponsors, administrators, and participants.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of cancellation of a public hearing on proposed rulemaking relating to the governing of source of income from certain space and ocean activities under section 863 of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service