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PROPOSED RULES: Escrow accounts, trusts, and other funds used during deferred exchanges of like-kind property; public hearing; Correction,
Published: 2006-03-07
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
PROPOSED RULES: Foreign and foreign-owned domestic corporations; required information returns; cross-reference,
Published: 2006-06-21
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
PROPOSED RULES: Expatriated entities and their foreign parents; section 7874 guidance; cross reference; Correction,
Published: 2006-08-16
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
PROPOSED RULES: Transfers of built-in losses; limitations,
Published: 2006-10-23
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
RULES: Residence rules source rules,
Published: 2006-11-14
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.
RULES: Qualified dividend income; election to treat as investment income; correction,
Published: 2006-04-12
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.
RULES: Multi-step transactions; effect of elections,
Published: 2006-07-05
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.
RULES: Stock held in employee stock ownership plan; dividends paid deduction,
Published: 2006-08-30
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
PROPOSED RULES: Katrina Emergency Tax Relief Act; Hurricane Katrina displaced individuals; taxable income reduction for housing; cross-reference,
Published: 2006-12-12
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
RULES: Stock or securities in exchange for, or with respect to, stock or securities in certain transactions; determination of basis; excess loss accounts treatment,
Published: 2006-01-26
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
PROPOSED RULES: Insurance companies; section 338 sale or acquisition of assets,
Published: 2006-05-08
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
RULES: Widely held fixed investment trusts; reporting requirements,
Published: 2006-08-03
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
PROPOSED RULES: General allocation and accounting regulations; tax-exempt bond proceeds,
Published: 2006-09-26
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
RULES: Computing depreciation; changes,
Published: 2006-12-28
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
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