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RULES: Income tax return preparers; credit or refund claims; CFR correction,
Published: 2006-03-10
CFR Correction
In Title 26 of the Code of Federal Regulations, part 1 (Sec.
1.1551 to end), revised as of April 1, 2005, on page 526, in Sec.
1.66961, paragraph (b), the third sentence is corrected by removing
``rified'', and adding in its place, ``Thus, the claim may be prepared
by the preparer's employer or by other persons. In all cases,
PROPOSED RULES: Business electronic filing and burden reduction; Correction,
Published: 2006-06-13
This document contains corrections to a notice of proposed
rulemaking by crossreference to temporary regulations that was
published in the Federal Register on Tuesday, May 30, 2006 (71 FR
30640) relating to guidance necessary to facilitate business electronic
filing and burden reduction.
PROPOSED RULES: Foreign corporations; interest expense deduction determination,
Published: 2006-08-17
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations under
sections 882 and 884 relating to the determination of the interest
expense deduction of foreign corporations engaged in a trade or
business within the United States. These regulations update the 1996
final interest expense
PROPOSED RULES: Expatriated entities and their foreign parents; section 7874 guidance; cross reference—; Public hearing canceled,
Published: 2006-10-25
This document cancels a public hearing on proposed regulations
under section 7874 of the Internal Revenue Code relating to the
determination of whether a foreign entity shall be treated as a
surrogate foreign corporation under section 7874(a)(2)(B).
PROPOSED RULES: Qualified business unit branches; transfers using profit and loss method of accounting, currency gain or loss calculation; public hearing canceled,
Published: 2006-11-14
This document cancels a public hearing on proposed regulations
concerning the determination of the items of income or loss of a
taxpayer with respect to a section 987 qualified business unit, as well
as the timing, amount, character and source of any section 987 gain or
loss.
PROPOSED RULES: Domestic entities; determining ownership by former shareholders or partners; Section 7874 guidance; cross-reference; hearing cancellation,
Published: 2006-04-20
This document cancels a public hearing on proposed 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 a surrogate foreign corporation
under section 7874 of
RULES: Computer software; Correction,
Published: 2006-07-06
This document contains a correction to temporary regulations
(TD 9262) that were published in the Federal Register on Thursday, June
1, 2006 (71 FR 31074) concerning the application of section 199 of the
Internal Revenue Code, which provides a deduction for income
attributable to domestic production activities, to certain transactions
involving
RULES: MACRS property and computer software; special depreciation allowance,
Published: 2006-08-31
This document contains final regulations relating to the
depreciation of property subject to section 168 of the Internal Revenue
Code (MACRS property) and the depreciation of computer software subject
to section 167. Specifically, these final regulations provide guidance
regarding the additional first year depreciation allowance provided by
RULES: Katrina Emergency Tax Relief Act; Hurricane Katrina displaced individuals; taxable income reduction for housing,
Published: 2006-12-12
This document contains temporary regulations relating to the
reduction in taxable income under section 302 of the Katrina Emergency
Tax Relief Act of 2005. The regulations affect taxpayers who provide
housing in their principal residences to individuals displaced by
Hurricane Katrina. The text of the temporary regulations also serves as
the text
PROPOSED RULES: Designated Roth accounts,
Published: 2006-01-26
This document contains proposed regulations under sections
402(g), 402A, 403(b), and 408A of the Internal Revenue Code (Code)
relating to designated Roth accounts. These regulations will affect
administrators of, employers maintaining, participants in, and
beneficiaries of section 401(k) and section 403(b) plans, as well as
owners and
PROPOSED RULES: Intercompany transactions; consolidated returns; withdrawn,
Published: 2006-05-08
This document withdraws a notice of proposed rulemaking (REG-
13126404) regarding the treatment of manufacturer incentive payments.
The proposed regulations were published in the Federal Register on
August 13, 2004 (69 FR 50112). After consideration of additional
issues, the IRS and Treasury Department have decided to withdraw the
proposed
PROPOSED RULES: Section 901 and related matters; taxpayer definition,
Published: 2006-08-04
These proposed regulations provide guidance relating to the
determination of who is considered to pay a foreign tax for purposes of
sections 901 and 903. The proposed regulations affect taxpayers that
claim direct and indirect foreign tax credits.
RULES: Foreign corporations; interest expense deduction determination; Correction,
Published: 2006-09-28
This document contains a correction to final and temporary
regulations (TD 9281), that were published in the Federal Register on
Thursday, August 17, 2006 (71 FR 47443). This regulation revised the
Income Tax Regulations relating to the determination of the interest
expense deduction of foreign corporations and applies to foreign
corporations
PROPOSED RULES: Qualified business unit branches; transfers using profit and loss method of accounting, currency gain or loss calculation; Correction,
Published: 2006-12-27
This document contains corrections to a notice of proposed
rulemaking that was published in the Federal Register on Thursday,
September 7, 2006 (71 FR 52876), regarding the determination of the
items of income or loss of a taxpayer with respect to a section 987
qualified business unit as well as the timing, amount, character and
source of any
RULES: Consolidated group regulations—; Foreign common parent; agent,
Published: 2006-03-14
This document contains temporary regulations under section
1502 that provide the IRS with the authority to designate a domestic
member of the consolidated group as a substitute agent to act as the
sole agent for the group where a foreign entity is the common parent.
The regulations affect corporations that join in the filing of a
consolidated
PROPOSED RULES: Repeal of tax interest on nonresident alien individuals and foreign corporations received from certain portfolio debt investments; public hearing,
Published: 2006-06-13
This document contains proposed regulations under sections 871
and 881 of the Internal Revenue Code (Code) relating to the exclusion
from gross income of portfolio interest paid to a nonresident alien
individual or foreign corporation. These regulations clarify how the
portfolio interest rules apply with respect to interest paid to a
partnership
RULES: Separate limitations application to dividends from noncontrolled section 902 corporations; Correction,
Published: 2006-08-21
This document contains corrections to temporary regulations
that were published in the Federal Register on Tuesday, April 25, 2006
(71 FR 24516) regarding the application of separate foreign tax credit
limitations to dividends received from noncontrolled section 902
corporations under section 904(d)(4).
RULES: Stock or securities in exchange for, or with respect to, stock or securities in certain transactions; determination of basis; excess loss accounts treatment; Correction,
Published: 2006-10-26
This document contains a correction to final and temporary
regulations (TD 9244), that were published in the Federal Register on
Thursday, January 26, 2006 (71 FR 4264). This regulation provides
guidance regarding the determination of the basis of stock or
securities received in exchange for, or with respect to, stock or
securities in certain
RULES: Credit for increasing research activities,
Published: 2006-11-09
This document contains final 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 businesses under common control. These final regulations
reflect changes made to section 41 by the Revenue Reconciliation Act of
1989, which
PROPOSED RULES: Employment tax returns filing time and deposit rule modifications; Public hearing canceled,
Published: 2006-04-19
This document provides notice of cancellation of a public
hearing on proposed rulemaking relating to the annual filing of Federal
employment tax deposits for employees in the Employers' Annual Federal
Tax Program (Form 944) under sections 6302 and 31.63021 of the
Internal Revenue Code.
RULES: Corporate distributions and adjustments; CFR correction,
Published: 2006-07-06
CFR Correction
In Title 26 of the Code of Federal Regulations, part 1 (Sec. Sec. 1.301 to 1.400),
[[Page 38262]]
revised as of April 1, 2006, on page 10, Sec. 1.3011 is corrected by adding paragraph (g) to read as follows:
Sec. 1.3011 Rules applicable with respect to distributions of money and other property.
* * * * *
(g) Reduction for
Part II: Treasury Department, Internal Revenue Service,
Published: 2006-09-07
This document contains proposed regulations that provide
guidance under section 987 of the Internal Revenue Code (Code)
regarding the determination of the items of income or loss of a
taxpayer with respect to a section 987 qualified business unit (section
987 QBU) as well as the timing, amount, character and source of any
section 987 gain or loss.
RULES: Credit for increasing research activities; Correction,
Published: 2006-12-15
Correction
In rule document E618909 beginning on page 65722 in the issue of Thursday, November 9, 2006, make the following correction:
Sec. 1.416 [Corrected]
On page 65730, in the first column, in Sec. 1.416(e), in Example
5, in paragraph (ii)(A), in the second to last line in the paragraph,
``The group credit is 0.20'' should read ``The
PROPOSED RULES: Excess loss accounts treatment,
Published: 2006-01-26
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations that provide
guidance under section 1502 that governs certain basis determinations
and adjustments of subsidiary stock in certain transactions involving
members of a consolidated group. The text of those regulations also
serves as
RULES: Consolidated group regulations—; Tax withholding on payments to foreign persons; information reporting requirements; correction,
Published: 2006-05-02
This document corrects final regulations and removal of
temporary regulations (TD 9253) that was published in the Federal
Register on Tuesday, March 14, 2006 (71 FR 13003) relating to the
withholding of tax under section 1441 on certain U.S. source income
paid to foreign persons and related requirements governing collection,
deposit, refunds, and