This document withdraws in part a notice of proposed rulemaking under section 468B of the Internal Revenue Code (Code) relating to the taxation and reporting of income earned on qualified settlement funds and certain other funds, trusts, and escrow accounts. This document also contains proposed regulations under section 468B regarding the taxation

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance needed to comply with amendments enacted by the American Jobs Creation Act of 2004, Public Law 108357, 118 Stat. 1418 (October 22, 2004) (AJCA) and the Gulf Opportunity Zone Act of 2005, Public Law 109135, 119 Stat. 2577 (December 22, 2005)

DEPARTMENT OF THE TREASURY : United States Mint

This document contains final regulations providing guidance on certain issues under section 411(d)(6) of the Internal Revenue Code (Code), including the interaction between the anticutback rules of section 411(d)(6) and the nonforfeitability requirements of section 411(a). These regulations also provide a utilization test under which certain plan

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a notice of proposed rulemaking (REG- 10936706) that was published in the Federal Register on Monday, August 7, 2006 (71 FR 44600) clarifying the circumstances in which accounts or notes receivable are ``acquired * * * for services rendered'' within the meaning of section 1221(a)(4) of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9296) that were published in the Federal Register on Thursday, November 9, 2006 (71 FR 65722) 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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations that were published in the Federal Register on Tuesday, January 3, 2006 (71 FR 11). These regulations relate to the annual filing of Federal employment tax returns and requirements for employment tax deposits for employers in the Employers' Annual Federal Tax Program (Form

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations under section 7874 of the Internal Revenue Code (Code) relating to the determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of these temporary regulations also serves as the text of the proposed regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects an advance notice of proposed rulemaking (REG11878806) that was published in the Federal Register on Wednesday, August 9, 2006 (71 FR 45474), that applies to Indian tribal governments and to State and local governments that issue bonds for the benefit of Indian tribal governments.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations that were published in the Federal Register on Tuesday, November 14, 2006 (71 FR 66232) relating to rules for determining bona fide residency in the following U.S. territories: American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the United States Virgin Islands.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects 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 recipients for whom

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations (TD 9244), that was 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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a proposed regulation which provides the translation rates that must be used when translating into dollars certain items and amounts transferred by a qualified business unit (QBU) to its home office or parent corporation for purposes of computing dollar approximate separate transactions method (DASTM) gain or loss.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations regarding the allocation of creditable foreign tax expenditures by partnerships. The regulations are necessary to clarify the application of
[[Page 61649]]
section 704(b) to allocations of creditable foreign tax expenditures. The final regulations affect partnerships and their partners.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

On September 26, 2006, on page 56072 of the Federal Register (71 FR 56072), a notice of proposed rulemaking and notice of public hearing announced that a public hearing relating to allocation and accounting of taxexempt bonds proceeds for purposes of the private activity bond restrictions will be held January 11, 2007, in the auditorium of the New

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document cancels a public hearing on proposed regulations that provides rules for testing the substantiality of an allocation under section 704(b) where the partners are lookthrough entities or members of a consolidated group.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations concerning the requirements for including insurance companies in a lifenonlife consolidated return. These regulations affect corporations filing life nonlife consolidated returns. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides changes of date and location for a public hearing on 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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

These proposed regulations clarify that if a bank is an S corporation within the meaning of section 1361(a)(1), its status as an S corporation does not affect the applicability of the special rules for banks under the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains correction to final regulations (TD 9292) that were published in the Federal Register on Thursday, October 19, 2006 (71 FR 61648) regarding the allocation of creditable foreign tax expenditures by partnerships.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations (TD 9244), that was 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

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 determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section 7874(a)(2)(B) of the Code. The text of those regulations also serves as the text of these proposed

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document cancels a public hearing on proposed regulations under sections 871 and 881 of the Internal Revenue Code relating to the exclusion from gross income of portfolio interest paid to a nonresident alien individual or foreign corporation.

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 that provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rule and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide rules for determining whether a controlled foreign corporation's (CFC's) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9243), that was published in the Federal Register on Thursday, January 26, 2006 (71 FR 4276). This final regulation amends the income tax regulations under various provisions of the Internal Revenue Code to account for statutory mergers and consolidations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service