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PROPOSED RULES: Consolidated group regulations—; Foreign common parent; agent; cross-reference,
Published: 2006-03-14
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing regulations that provide the IRS
with the authority to designate a domestic member of the consolidated
group as a substitute agent to act as the sole agent for the group
where a foreign entity is the common parent. These regulations affect
corporations
PROPOSED RULES: Designated Roth accounts; Hearing,
Published: 2006-06-08
This document provides notice of public hearing on proposed
regulations under sections 402(g), 402A, 403(b), and 408A of the
Internal Revenue Code (Code) relating to designated Roth accounts.
RULES: Stock dispositions; suspension of losses; Correction,
Published: 2006-08-21
This document contains corrections to final regulations that
were published in the Federal Register on Tuesday, March 14, 2006 (71
FR 13008) regarding guidance on suspension of losses on certain stock
dispositions.
PROPOSED RULES: Section 901 and related matters; taxpayer definition; Correction,
Published: 2006-10-31
This document contains corrections to notice of proposed
rulemaking and notice of public hearing that was published in the
Federal Register on Friday, August 4, 2006 (71 FR 44240) relating to
the determination of who is considered to pay a foreign tax for
purposes of sections 901 and 903.
RULES: Private activity bonds; definition; correction,
Published: 2006-01-12
This document corrects final regulations (TD 9234) that was
published in the Federal Register on Monday, December 19, 2005 (70 FR
75028). The final regulations relates to the definition of private
activity bond applicable to taxexempt bonds issued by State and local
governments.
PROPOSED RULES: Redemptions taxable as dividends; withdrawn,
Published: 2006-04-19
This document withdraws a notice of proposed rulemaking
relating to redemptions of stock in which the redemption proceeds are
treated as a dividend distribution. The proposed regulations were
published on October 18, 2002 (67 FR 64331). After consideration of the
comments received, the IRS and Treasury Department have decided to
withdraw the
PROPOSED RULES: Household and dependent care services necessary for gainful employment; expenses; Correction,
Published: 2006-07-06
This document contains a correction to notice of proposed
rulemaking that was published in the Federal Register on Wednesday, May
24, 2006 (71 FR 29847) regarding the credit for expenses for household
and dependent care services necessary for gainful employment.
PROPOSED RULES: Railroad track maintenance credit; cross-reference; hearing,
Published: 2006-09-08
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations under
section 45G of the Internal Revenue Code relating to the railroad track
maintenance credit determined for qualified railroad track maintenance
expenditures paid or incurred by a Class II or Class III railroad and
other
RULES: Income attributable to domestic production activities; deduction; Correction,
Published: 2006-12-15
Correction
In rule document E617402 beginning on page 61662 in the issue of Thursday, October 19, 2006, make the following correction:
Sec. 1.1990 [Corrected]
On page 61665, in the second column, in Sec. 1.1990, under Sec. 1.1997(b)(4),
``(4)Losses used to reduce taxable income of expanded affiliated group. [Reserved].''
should
RULES: Alternative method for determining tax book value of assets; allocation and apportionment of expenses,
Published: 2006-01-30
This document contains final regulations providing an
alternative method of valuing assets for purposes of apportioning
expenses under the tax book value method of Sec. 1.8619T. The
alternative tax book value method, which is elective, allows taxpayers
to determine, for purposes of apportioning expenses, the tax book value
of all tangible
PROPOSED RULES: Life-nonlife consolidated returns; tacking rule requirements; cross-reference,
Published: 2006-04-25
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations relating to
the requirements for including insurance companies in a lifenonlife
consolidated return. The text of those regulations also serves as the
text of these proposed regulations. These regulations affect
corporations filing
RULES: Stock transfer rules; carryover of tax attributes,
Published: 2006-08-08
This document contains final regulations 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 described in both
section 367(b) and section 381 of the Internal Revenue Code (Code).
RULES: Stock transfer rules; carryover of tax attributes; Correction,
Published: 2006-10-02
This document contains a 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
PROPOSED RULES: Annuity contracts; property exchanges; Hearing location change,
Published: 2006-12-27
On October 18, 2006, on page 61441 of the Federal Register (71
FR 61441), a notice of proposed rulemaking and notice of public hearing
announced that a public hearing concerning guidance on the taxation of the
[[Page 77654]]
exchange of property for an annuity contract will be held February 16,
2007 in the auditorium of the New Carrollton Federal
PROPOSED RULES: Passive foreign investment company purging elections; guidance; cross-reference; public hearing canceled,
Published: 2006-03-16
This document provides notice of cancellation of a public
hearing on a notice of proposed rulemaking by crossreference to
temporary regulations, notice of proposed rulemaking, and notice of
public hearing providing certain elections for taxpayers, who in
limited circumstances, continue to be subject to the excess
distribution regime of section
RULES: Stock dispositions; suspension of losses; Correction,
Published: 2006-06-08
This document contains corrections to final regulations that
were published in the Federal Register on Tuesday, March 14, 2006 (71
FR 13008). The regulations apply when a member of a consolidated group
transfers subsidiary stock at a loss. They also apply when a member
holds loss shares of subsidiary stock and the subsidiary ceases to be a
member
Part II: Treasury Department, Internal Revenue Service,
Published: 2006-08-21
This document contains proposed regulations that explain how
section 263(a) of the Internal Revenue Code (Code) applies to amounts
paid to acquire, produce, or improve tangible property. The proposed
regulations clarify and expand the standards in the current regulations
under section 263(a), as well as provide some brightline tests (for
example,
PROPOSED RULES: General allocation and accounting regulations; tax-exempt bond proceeds; Correction,
Published: 2006-11-22
This document contains corrections to a notice of proposed
rulemaking and notice of public hearing that was published in the
Federal Register on Tuesday, September 26, 2006 (71 FR 56072) relating
to the allocation of, and accounting for, taxexempt bond proceeds for
purposes of the private activity bond restrictions that apply under
section 141 of
RULES: Partnerships; treatment of controlled foreign corporation's distributive share of partnership income; guidance under subpart F,
Published: 2006-01-17
This document contains final and temporary regulations
providing guidance under subpart F relating to partnerships. The
temporary regulations add 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
PROPOSED RULES: Mortality tables for determining current liability; update; hearing canceled,
Published: 2006-04-17
This document provides notice of cancellation of a public
hearing on proposed rulemaking that relates to the affect plans
sponsors and administrators, and participants in and beneficiaries of
certain retirement plans under section 412(l)(7) of the Internal
Revenue Code and section 302(d)(7) of the Employee Retirement Income
Security Act of 1974.
RULES: Gross proceeds payments to attorneys; reporting requirements,
Published: 2006-07-13
This document contains final regulations relating to the
reporting of payments of gross proceeds to attorneys. The regulations
reflect changes to the law made by the Taxpayer Relief Act of 1997
(1997 Act). The final regulations will affect attorneys who receive
payments of gross proceeds on behalf of their clients and will affect
certain payors
RULES: Attained age of the insured under (section 7702),
Published: 2006-09-13
This document contains final regulations 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.
RULES: Corporate reorganizations and distributions,
Published: 2006-12-19
This document contains temporary regulations under section 368
of the Internal Revenue Code of 1986 (Code). The temporary regulations
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