This document withdraws the remaining portion of the notice of proposed rulemaking published in the Federal Register on June 3, 1971 (36 FR 10787) and contains proposed regulations relating to the tax treatment of certain transfers of partnership equity in connection with the performance of services. The proposed regulations provide that the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

CFR Correction

In Title 26 of the Code of Federal Regulations, Part 1 (Sec. 1.1551 to End), revised as of April 1, 2005, in Sec. 1.60451(g)(4), Example 9, on page 252, second column, the last paragraph designated (i) and on page 253 first column, first complete paragraph designated (ii) are removed.
[FR Doc. 0555506 Filed 71805; 8:45 am]

INTERNAL REVENUE SERVICE : Internal Revenue Service

This document contains final regulations removing provisions of the Income Tax Regulations that apply a lookthrough rule to assets of a nonregistered partnership for purposes of satisfying the diversification requirements of section 817(h) of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final regulations (TD 9222) that were published in the Federal Register on Thursday, August 25, 2005 (70 FR 49864). The final regulations under section 951(a) of the Internal Revenue Code (Code) provide guidance for determining a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a notice of proposed rulemaking (REG- 10852400) that was published in the Federal Register on Wednesday, May 18, 2005 (70 FR 28743). The document contains regulations providing guidance under section 1446 of the Internal Revenue Code relating to the circumstances under which a partnership may take partnerlevel deductions and

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking and notice of public hearing that was published in the Federal Register on Wednesday, December 21, 2005 (70 FR 75762). These regulations provide guidance on the normalization requirements applicable to public utilities that benefit (or have benefited) from accelerated depreciation

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations that were published in the Federal Register on Monday, August 29, 2005 (70 FR 50967) regarding the amount includible in a distributee's income when life insurance contracts are distributed by a qualified retirement plan and regarding the treatment of property sold by a qualified retirement

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed amendments to regulations under section 951(a) of the Internal Revenue Code (Code) regarding 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 previously excluded

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9171), that were published in the Federal Register on Tuesday, December 28, 2004 (69 FR 77625) relating to the new markets tax credit under section 45D.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 1502 of the Internal Revenue Code that govern the application of section 108 when a member of a consolidated group realizes discharge of indebtedness income. These final regulations affect corporations filing consolidated returns.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document sets forth an elective safe harbor for dealers in securities, dealers in commodities, and traders in securities and commodities that permits these taxpayers to make an election pursuant to which the values of positions reported on certain financial statements are the fair market values of those positions for purposes of section 475

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document amends the applicability date of final regulations under sections 883(a) and (c) (TD 9087) which were published in the Federal Register on August 26, 2003 (68 FR 51394). Those final regulations relate to income derived by a foreign corporation from the international operation of ships or aircraft.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations that modify the rules relating to qualified amended returns by providing additional circumstances that end the period within which a taxpayer may file an [[Page 10038]]
amended return that constitutes a qualified amended return. These regulations provide that the period for filing a qualified amended

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final regulations (TD 9222) that were published in the Federal Register on Thursday, August 25, 2005 (70 FR 49864).

The final regulations under section 951(a) of the Internal Revenue Code (Code) provide guidance for determining a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's)

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to certain changes made to the law by the Tax Reform Act of 1984. These final regulations are necessary to update, clarify, and reorganize the rules and procedures for making payments of estimated income
[[Page 52300]]
tax by individuals. These final regulations do not impose any new requirements

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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