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126. Agent for a Consolidated Group With Foreign Common Parent

PROPOSED RULES: Consolidated group regulations—; Foreign common parent; agent; cross-reference,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

127. Designated Roth Accounts Under Section 402A; Hearing

PROPOSED RULES: Designated Roth accounts; Hearing,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

128. Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correcting Amendment

RULES: Stock dispositions; suspension of losses; Correction,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

129. Definition of Taxpayer for Purposes of Section 901 and Related Matters; Correction

PROPOSED RULES: Section 901 and related matters; taxpayer definition; Correction,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

130. Obligations of States and Political Subdivisions; Correction

RULES: Private activity bonds; definition; correction,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

131. Withdrawal of Proposed Regulations Relating to Redemptions Taxable as Dividends

PROPOSED RULES: Redemptions taxable as dividends; withdrawn,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

132. Expenses for Household and Dependent Care Services Necessary for Gainful Employment; Correction

PROPOSED RULES: Household and dependent care services necessary for gainful employment; expenses; Correction,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

133. Railroad Track Maintenance Credit

PROPOSED RULES: Railroad track maintenance credit; cross-reference; hearing,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

134. TIPRA Amendments to Section 199

RULES: Income attributable to domestic production activities; deduction; Correction,

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

DEPARTMENT OF THE TREASURY : Internal Revenue Service

135. Allocation and Apportionment of Expenses Alternative Method for Determining Tax Book Value of Assets

RULES: Alternative method for determining tax book value of assets; allocation and apportionment of expenses,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

136. Guidance Under Section 1502; Amendment of Tacking Rule Requirements of Life-Nonlife Consolidated Regulations

PROPOSED RULES: Life-nonlife consolidated returns; tacking rule requirements; cross-reference,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

137. Stock Transfer Rules: Carryover of Earnings and Taxes

RULES: Stock transfer rules; carryover of tax attributes,

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).
DEPARTMENT OF THE TREASURY : Internal Revenue Service

138. Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

RULES: Stock transfer rules; carryover of tax attributes; Correction,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

139. Exchanges of Property for an Annuity

PROPOSED RULES: Annuity contracts; property exchanges; Hearing location change,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

140. Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Hearing Cancellation

PROPOSED RULES: Passive foreign investment company purging elections; guidance; cross-reference; public hearing canceled,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

141. Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correction

RULES: Stock dispositions; suspension of losses; Correction,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

142. Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Part II: Treasury Department, Internal Revenue Service,

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,
DEPARTMENT OF THE TREASURY : Treasury Department

143. General Allocation and Accounting Regulations Under Section 141; Correction

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

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

144. Guidance Under Subpart F Relating to Partnerships

RULES: Partnerships; treatment of controlled foreign corporation's distributive share of partnership income; guidance under subpart F,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

145. Updated Mortality Tables for Determining Current Liability; Hearing Cancellation

PROPOSED RULES: Mortality tables for determining current liability; update; hearing canceled,

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

146. Reporting of Gross Proceeds Payments to Attorneys

RULES: Gross proceeds payments to attorneys; reporting requirements,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

147. Attained Age of the Insured Under Section 7702

RULES: Attained age of the insured under (section 7702),

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.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

148. Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

RULES: Corporate reorganizations and distributions,

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
DEPARTMENT OF THE TREASURY : Internal Revenue Service

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