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51. Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

PROPOSED RULES: Escrow accounts, trusts, and other funds used during deferred exchanges of like-kind property; public hearing; Correction,

Correction

In proposed rule document 061038 beginning on page 6231 in the issue of Tuesday, February 7, 2006, make the following corrections: Sec. 1.468B6 [Corrected]

1. On page 6237, in Sec. 1.468B6(e), in the table, in the fourth column, the heading ``T's share*'' should read ``T's share* (percent)''.

2. On the same page, in the same

DEPARTMENT OF THE TREASURY : Internal Revenue Service

52. Information Returns Required With Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic

PROPOSED RULES: Foreign and foreign-owned domestic corporations; required information returns; cross-reference,

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations to clarify existing guidance under sections 6038 and 6038A of the Internal Revenue Code (Code) with respect to the information required to be furnished regarding certain related party transactions of certain foreign corporations and
DEPARTMENT OF THE TREASURY : Internal Revenue Service

53. Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Correction Notice

PROPOSED RULES: Expatriated entities and their foreign parents; section 7874 guidance; cross reference; Correction,

This document contains corrections to notice of proposed rulemaking by crossreference to temporary regulations and notice of public hearing that was published in the Federal Register on Tuesday, June 6, 2006 (71 FR 32495) relating to the determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section
DEPARTMENT OF THE TREASURY : Internal Revenue Service

54. Limitations on Transfers of Built-in Losses

PROPOSED RULES: Transfers of built-in losses; limitations,

This document contains proposed regulations under section 362(e)(2) of the Internal Revenue Code of 1986 (Code). The proposed regulations reflect changes made to the law by the American Jobs Creation Act of 2004. These proposed regulations provide guidance regarding the determination of the bases of assets and stock transferred in certain
DEPARTMENT OF THE TREASURY : Internal Revenue Service

55. Residence Rules Involving U.S. Possessions

RULES: Residence rules source rules,

This document contains final regulations that provide 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 under section 937(a) of the Internal Revenue Code.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

56. Time and Manner of Making Section 163(d)(4)(B) Election To Treat Qualified Dividend Income as Investment Income;

RULES: Qualified dividend income; election to treat as investment income; correction,

This document contains a correction to a temporary regulation (TD 9191) that was published in the Federal Register on Friday, March 18, 2005 (70 FR 13100), relating to the time and manner of making section 163(d)94)(B) election to treat qualified dividend income as investment income.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

57. Effect of Elections in Certain Multi-Step Transactions

RULES: Multi-step transactions; effect of elections,

This document contains final regulations that give effect to section 338(h)(10) elections in certain multistep transactions. These final regulations are necessary in order to provide taxpayers with guidance regarding the validity of certain elections made under section 338(h)(10). These final regulations affect corporations and their shareholders.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

58. Dividends Paid Deduction for Stock Held in Employee Stock Ownership Plan

RULES: Stock held in employee stock ownership plan; dividends paid deduction,

This document contains final regulations under sections 162(k) and 404(k) of the Internal Revenue Code (Code) providing that a payment in redemption of employer securities held by an employee stock ownership plan (ESOP) is not deductible. These regulations generally affect administrators of, employers maintaining, participants in, and
DEPARTMENT OF THE TREASURY : Internal Revenue Service

59. Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals

PROPOSED RULES: Katrina Emergency Tax Relief Act; Hurricane Katrina displaced individuals; taxable income reduction for housing; cross-reference,

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing 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 that provide housing in their principal residences to individuals displaced by Hurricane
DEPARTMENT OF THE TREASURY : Internal Revenue Service

60. Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in

RULES: Stock or securities in exchange for, or with respect to, stock or securities in certain transactions; determination of basis; excess loss accounts treatment,

This document contains final regulations under section 358 that provide guidance regarding the determination of the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions. This document also contains temporary regulations under section 1502 that govern certain basis determinations and
DEPARTMENT OF THE TREASURY : Internal Revenue Service

61. Application of Section 338 to Insurance Companies; Correction

PROPOSED RULES: Insurance companies; section 338 sale or acquisition of assets,

This document corrects a notice of proposed rulemaking that was published in the Federal Register on Monday, April 10, 2006 (71 FR 18053).

The document contains temporary regulations providing guidance under section 197 that apply to the treatment of certain insurance contracts assumed in an assumption reinsurance transaction and section 338

DEPARTMENT OF THE TREASURY : Internal Revenue Service

62. Reporting Rules for Widely Held Fixed Investment Trusts

RULES: Widely held fixed investment trusts; reporting requirements,

This document contains final and temporary regulations amending Sec. 1.6715, a provision which provides reporting rules for widely held fixed investment trusts (WHFITs). These regulations clarify and simplify reporting for trustees and middlemen of nonmortgage widely held fixed investment trusts (NMWHFITs). The text of these final and temporary
DEPARTMENT OF THE TREASURY : Internal Revenue Service

63. General Allocation and Accounting Regulations Under Section 141

PROPOSED RULES: General allocation and accounting regulations; tax-exempt bond proceeds,

This document contains proposed regulations on the allocation of, and accounting for, taxexempt bond proceeds for purposes of the private activity bond restrictions that apply under section 141 of the Internal Revenue Code (Code) and that apply in modified form to qualified 501(c)(3) bonds under section 145 of the Code. The proposed regulations
DEPARTMENT OF THE TREASURY : Internal Revenue Service

64. Changes in Computing Depreciation

RULES: Computing depreciation; changes,

This document contains regulations relating to a change in computing depreciation or amortization as well as a change from a nondepreciable or nonamortizable asset to a depreciable or amortizable asset (or vice versa). Specifically, these regulations provide guidance to any taxpayer that makes a change in depreciation or amortization on whether
DEPARTMENT OF THE TREASURY : Internal Revenue Service

65. Income Taxes

RULES: Income tax return preparers; credit or refund claims; CFR correction,

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,

DEPARTMENT OF THE TREASURY : Internal Revenue Service

66. Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction; Correction

PROPOSED RULES: Business electronic filing and burden reduction; Correction,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

67. Determination of Interest Expense Deduction of Foreign Corporations

PROPOSED RULES: Foreign corporations; interest expense deduction determination,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

68. Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Hearing Cancellation

PROPOSED RULES: Expatriated entities and their foreign parents; section 7874 guidance; cross reference—; Public hearing canceled,

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).
DEPARTMENT OF THE TREASURY : Internal Revenue Service

69. Income and Currency Gain or Loss With Respect to a Section 987 QBU; Hearing Cancellation

PROPOSED RULES: Qualified business unit branches; transfers using profit and loss method of accounting, currency gain or loss calculation; public hearing canceled,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

70. Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities;

PROPOSED RULES: Domestic entities; determining ownership by former shareholders or partners; Section 7874 guidance; cross-reference; hearing cancellation,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

71. Computer Software Under Section 199(c)(5)(B); Correction

RULES: Computer software; Correction,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

72. Special Depreciation Allowance

RULES: MACRS property and computer software; special depreciation allowance,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

73. Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals

RULES: Katrina Emergency Tax Relief Act; Hurricane Katrina displaced individuals; taxable income reduction for housing,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

74. RIN 1545-BF04

PROPOSED RULES: Designated Roth accounts,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

75. Withdrawal of Proposed Regulations Regarding Intercompany Transactions; Manufacturer Incentive Payments

PROPOSED RULES: Intercompany transactions; consolidated returns; withdrawn,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

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