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

This document provides a change of location for a public hearing on proposed regulations under sections 402(g), 402A, 403(b), and 408A of the Internal Revenue Code relating to designated Roth accounts.

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

This document contains final regulations that address the interaction of section 304 and section 367. These regulations provide that section 367(a) and (b) do not apply to a deemed section 351 exchange resulting from a section 304(a)(1) transaction. These regulations may apply to taxpayers transferring stock to related foreign corporations.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document amends final regulations concerning statutory mergers and consolidations under section 368(a)(1)(A) of the Internal Revenue Code. These regulations affect corporations engaging in statutory mergers and consolidations, and their shareholders. This amendment provides transitional relief for certain transactions initiated before January

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a notice of proposed rulemaking (REG- 13586602) that was published in the Federal Register on Friday, June 2, 2006 (71 FR 31985) providing guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations concerning the amendments made by the Tax Increase Prevention and Reconciliation Act of 2005 to section 199 of the Internal Revenue Code. The temporary regulations also contain a rule concerning the use of losses incurred by members of an expanded affiliated group. Section 199 provides a

DEPARTMENT OF THE TREASURY : Internal Revenue Service

On October 19, 2006, on page 61692 of the Federal Register (71 FR 61692), a notice of proposed rulemaking by crossreference to temporary regulations and notice of public hearing announced that a public hearing concerning the application of section 199, which provides a deduction for income attributable to domestic production activities will be

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to a cancellation of public hearing notice which was published in the Federal Register on Friday, March 3, 2006 (71 FR 10940) relating to corporate estimated taxes.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations under section 1248 of the Internal Revenue Code (Code) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions. The proposed

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations that were published in the Federal Register on Thursday, June 1, 2006 (71 FR 31268) concerning the deduction for income attributable to domestic production activities under section 199.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final and temporary regulations (TD 9293) that were published in the Federal Register on Thursday, October 19, 2006 (71 FR 61662) concerning the amendments made by the Tax Increase Prevention and Reconciliation Act of 2005 to section 199 of the Internal Revenue Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects temporary regulations (TD 9232) that were published in the Federal Register on Thursday, December 8, 2005 (70 FR 72908) that provide certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of [[Page 4042]]
section 1291 even though the foreign corporation in which they own stock is no

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects final and temporary regulations (TD 9257) that were published in the Federal Register on Monday, April 10, 2006 (71 FR 17990) applying to a deemed sale or acquisition of an insurance company's assets pursuant to an election under section 338 of the Internal Revenue Code, to a sale or acquisition of an insurance trade or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 410(b) of the Internal Revenue Code. The final regulations permit, in certain circumstances, employees of a taxexempt organization described in section 501(c)(3) to be excluded for the purpose of testing whether a section 401(k) plan (or a section 401(m) plan that is provided under the same

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a correction to notice of proposed rulemaking by crossreference to temporary regulations and notice of public hearing that was published in the Federal Register on Wednesday, August 16, 2006 (71 FR 47158) relating to the determination of whether a foreign entity shall be treated as a surrogate foreign

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations that provide guidance concerning requirements under section 409(p) of the Internal Revenue Code for employee stock ownership plans (ESOPs) holding stock of Subchapter S corporations. These final regulations generally affect plan sponsors of, and participants in, ESOPs holding stock of Subchapter S

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 951(a) of the Internal Revenue Code (Code) regarding a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

This document corrects a notice of proposed rulemaking (REG- 13586602) that was published in the Federal Register on Friday, June 2, 2006 (71 FR 31985) providing guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved 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 concerning the application of section 199 of the Internal Revenue Code, which provides a deduction for income attributable to domestic production activities. The text of those regulations also serves as the text of these proposed

DEPARTMENT OF THE TREASURY : Internal Revenue Service

On October 19, 2006, on page 61693 of the Federal Register (71 FR 61693), a notice of proposed rulemaking and notice of public hearing announced that a public hearing concerning applying the private security or payment test for State and local governmental issuers of taxexempt bonds will be held February 13, 2007 in the auditorium of the New

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking by crossreference to temporary regulations that was published in the Federal Register on Thursday, January 26, 2006 (71 FR 4319). These regulations provide guidance under section 1502 that governs certain basis determinations and adjustments of subsidiary stock in certain

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations 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 computer software. The regulations will affect taxpayers engaged in certain domestic production activities

DEPARTMENT OF THE TREASURY : Internal Revenue Service