This document contains corrections to final regulations (TD 9272) that were published in the Federal Register on Tuesday, August 1, 2006 (71 FR 43363) relating to income that is associated with a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) and that is allocated through certain entities to foreign persons who have

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains correction to final regulations (TD 9273) that were published in the Federal Register on Tuesday, August 8, 2006 (71 FR 44887) addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to temporary regulations 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 section 1291 even though the foreign corporation in which they own stock is no longer

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 1502 of the Internal Revenue Code. Example 13 of the intercompany transaction regulations illustrates the treatment of manufacturer incentive payments. Because a premise underlying the example is under reconsideration, these final regulations remove and reserve this example. The regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides a change of location for a public hearing on proposed regulations under section 199 of the Internal Revenue Code. The regulations provide a deduction for income attributable to domestic production activities to certain transactions involving computer software.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that would generally eliminate countrybycountry reporting by a regulated investment company (RIC) to its shareholders of foreign source income that the RIC takes into account and foreign taxes that it pays. RICs will continue to report this information directly to the IRS. The regulations will affect

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final and temporary regulations (TD 9278) that was published in the Federal Register on Friday, August 4, 2006 (71 FR 44466) regarding the treatment of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document cancels a public hearing on proposed regulations and withdraws proposed regulations relating to corporate estimated taxes.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects a notice of proposed rulemaking by crossreference to temporary regulations (REG11157806) that was published in the Federal Register on Thursday, June 1, 2006 (71 FR 31128). The document contains temporary regulations concerning the application of section 199 of the Internal Revenue Code, which provides a deduction for income

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9270) that were published in the Federal Register on Thursday, July 13, 2006 (71 FR 39548) relating to the reporting of payments of gross proceeds to attorneys.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations modifying the standards for treating payments in lieu of taxes (PILOTs) as generally applicable taxes for purposes of the private security or payment test under section 141 of the Internal Revenue Code (Code). The proposed regulations provide State and local governmental issuers of taxexempt bonds with

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations amending Sec. 1.671- 5 which provides reporting rules for widely held fixed investment trusts (WHFITs). These final regulations clarify and simplify reporting for trustees and middlemen of nonmortgage widely held fixed investment trusts (NMWHFITs). These final regulations also provide temporary safe harbor

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 417(a)(3) of the Internal Revenue Code concerning content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable under certain retirement plans. These regulations affect sponsors, administrators, participants,

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, to certain transactions involving computer software. The text of those

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document cancels a public hearing on proposed 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.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Correction

In proposed rule document E617301 beginning on page 61441 in the issue of Wednesday, October 18, 2006, make the following correction: Sec. 1.10011 [Corrected]

On page 61445, in the first column, in Sec. 1.10011(J)(2)(ii), in the next to last line, ``April 18, 2006'' should read ``April 18, 2007.''
[FR Doc. Z617301 Filed 12706;

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations amending the income tax regulations under various provisions of the Internal Revenue Code (Code) to account for statutory mergers and consolidations under section 368(a)(1)(A) (including such reorganizations described in section 368(a)(2)(D) or (E)) involving one or more foreign corporations. These final

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations that were published in the Federal Register on Friday, March 24, 2006 (71 FR 14798) concerning content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable under certain retirement plans.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations relating to income that is associated with a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) and that is allocated through certain entities to foreign persons who have invested in those entities. The regulations accelerate the time when income is recognized for withholding tax

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations that were published in the Federal Register on August 9, 2006 (71 FR 45379) that provide 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

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 affect component members of controlled groups of corporations and consolidated groups filing lifenonlife Federal income tax returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type

DEPARTMENT OF THE TREASURY : Internal Revenue Service

CFR Correction

In Title 26 of the Code of Federal Regulations, part 1 (Sec. Sec. 1.61 to 1.169), revised as of April 1, 2005, on page 495, reinstate Sec. 1.1182 to read as follows:
Sec. 1.1182 Contribution in aid of construction.
(a) Special rule for water and sewerage disposal utilities(1) In general. For purposes of section 118, the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 382 of the Internal Revenue Code of 1986. The final regulations affect loss corporations and provide guidance on whether a loss corporation has an owner shift where a qualified trust described in section 401(a) distributes an ownership interest in an entity.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9270) that were published in the Federal Register on Thursday, July 13, 2006 (71 FR 39548) relating to the reporting of payments of gross proceeds to attorneys.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document corrects the final regulation (TD 9287) that was published in the Federal Register on Wednesday, September 13, 2006 (71 FR 53967), explaining how to determine the attained age of an insured for purposes of testing whether a contract qualifies as a life insurance contract for Federal income tax purposes.

DEPARTMENT OF THE TREASURY : Internal Revenue Service