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51. Qualified Amended Returns

RULES: Qualified amended returns; temporary regulations,

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

52. Guidance Under Section 951 for Determining Pro Rata Share; Correction

RULES: Pro rata share determination; section 951 guidance; correction,

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

53. Updating Estimated Income Tax Regulations Under Section 6654

RULES: Estimated income tax regulations; update,

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

54. Transactions Involving the Transfer of No Net Value

PROPOSED RULES: Transactions involving the transfer of no net value,

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

55. Application of Section 409A to Nonqualified Deferred Compensation Plans

Part II: Treasury Department, 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

56. Converting an IRA Annuity to a Roth IRA

RULES: Taxpayer Relief Act—; Roth IRAs,

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

57. Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit

PROPOSED RULES: Relative values of optional forms of benefit; disclosure,

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

58. Section 704(c), Installment Obligations and Contributed Contracts

RULES: Installment obligations and contributed contracts,

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

59. Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign

PROPOSED RULES: Section 367 stock transfers involving foreign corporations in transactions governed by section 304,

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

60. Section 704(c) Installment Obligations and Contributed Contracts; Correction

RULES: Installment obligations and contributed contracts; Correction,

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

61. Designated Roth Contributions to Cash or Deferred Arrangements Under Section 401(k)

PROPOSED RULES: 401(k) plans; designated Roth contributions to cash or deferred arrangements,

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

62. Guidance Under Section 355(e); Recognition of Gain on Certain Distributions of Stock or Securities in Connection With

RULES: Stock or securities in acquisition; recognition of gain on distributions,

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

63. Dual Consolidated Loss Regulations; Hearing Cancellation

PROPOSED RULES: Dual consolidated losses—; Hearing cancellation,

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

64. Loss Limitation Rules

RULES: Loss limitation rules; Correction,

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

65. Source of Income From Certain Space and Ocean Activities; Source of Communications Income; Correction

PROPOSED RULES: Space and ocean activities and communications; source of income; public hearing; Correction,

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

66. Converting an IRA Annuity to a Roth IRA

PROPOSED RULES: Taxpayer Relief Act—; Roth IRAs,

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

67. Section 1374 Effective Dates; Correction

RULES: S corporations; section 1374 effective dates; correction,

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

68. Prohibited Allocations of Securities in an S Corporation

RULES: S corporation securities; prohibited allocations; correction,

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

69. Assumption of Liabilities

PROPOSED RULES: Section 752 assumption of partner liabilities; cross reference,

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

70. Guidance Regarding the Simplified Service Cost Method and the Simplified Production Method

RULES: Simplified service cost method and simplified production method,

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

71. Qualified Amended Returns

PROPOSED RULES: Qualified amended returns; temporary regulations; cross-reference,

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

72. Transactions Involving the Transfer of No Net Value; Correction

PROPOSED RULES: Transactions involving the transfer of no net value; correction,

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

73. Qualified Amended Returns; Correction

RULES: Qualified amended returns; temporary regulations; Correction,

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

74. Section 1374 Effective Dates

RULES: S corporations; section 1374 effective dates,

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

75. Mortgage Revenue Bonds

RULES: Mortgage revenue bonds,

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
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