This document contains final regulations which provide the translation rates that must be used when translating into dollars certain items and amounts transferred by a qualified business unit (QBU) to its home office or parent corporation for purposes of computing dollar approximate separate transactions method (DASTM) gain or loss. This

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Section 42(h)(6)(F) requires the Secretary to prescribe such regulations as may be necessary or appropriate to carry out the provisions of section 42(h)(6)(F), including regulations to prevent the manipulation of the qualified contract amount. This document contains proposed regulations that provide guidance concerning taxpayers' requests to

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains correction to temporary regulations (TD 9335) that were published in the Federal Register on Friday, July 6, 2007 (72 FR 36869) under section 6033(a)(2) of the Internal Revenue Code that provide rules regarding the form, manner and timing of disclosure obligations with respect to prohibited tax shelter transactions to which

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations (TD 9339) that were published in the Federal Register on Friday, September 14, 2007 (72 FR 52470) providing guidance to state and local governments that issue qualified zone academy bonds and to banks, insurance companies, and other taxpayers that hold those bonds on the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document removes the final regulation for Sec. 1.1561-2, amends Sec. Sec. 1.15612T and 1.15631T, and adds Sec. 1.150247T. These temporary regulations affect component members of a controlled group of corporations and consolidated groups filing lifenonlife Federal income tax returns. These temporary regulations provide guidance for

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to temporary regulations that was published in the Federal Register on Tuesday, December 19, 2006 (71 FR 75879) regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9323) that were published in the Federal Register on Thursday, April 12, 2007 (72 FR 18386) 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

This document contains final regulations under section 1502 concerning the requirements for including insurance companies in a lifenonlife consolidated return. These regulations conform the consolidated return rules to certain changes in law. These regulations affect corporations filing lifenonlife consolidated returns.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to the allocation of purchase price in certain deemed and actual asset acquisitions under sections 338 and 1060. These regulations affect sellers and purchasers of nuclear power plants or of the stock of corporations that own nuclear power plants.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains temporary regulations concerning information reporting on employerowned life insurance contracts under section 6039I of the Internal Revenue Code (Code). This temporary regulation is necessary to provide taxpayers with immediate guidance as to how the requirements of section 6039I should be applied. The temporary regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations relating to the depreciation of property subject to the accelerated cost recovery system under section 168 of the Internal Revenue Code (MACRS property). Specifically, these final regulations provide guidance on how to depreciate MACRS property acquired in a likekind exchange under section 1031 or as a

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to a notice of proposed rulemaking (REG12336503) that was published in the Federal Register on Tuesday, May 8, 2007 (72 FR 26012) providing guidance on issues involving the active trade or business requirement under section 355(b), including guidance resulting from the enactment of section 355(b)(3).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document proposes changes to the regulations concerning the diversification requirements of section 817(h) of the Internal Revenue Code (Code). The proposed changes would expand the list of holders whose beneficial interests in an investment company, partnership, or trust do not prevent a segregated asset account from looking through to the

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9340) that were published in the Federal Register on Thursday, July 26, 2007 (72 FR 41128) providing updated guidance on section 403(b) contracts of public schools and taxexempt organizations described in section 501(c)(3). These regulations will affect sponsors of section 403(b)

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to temporary regulations (TD 9366) that were published in the Federal Register on Thursday, November 15, 2007 (72 FR 64147) describing the time and manner in which certain taxexempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations under section 1502 of the Internal Revenue Code (Code). These regulations provide guidance to corporations filing consolidated returns. These regulations apply an antiavoidance rule and revise an antiloss reimportation rule that applies following a disposition of stock of a subsidiary at a

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 modify final regulations issued under section 883(a) and (c) of the Internal Revenue Code (Code), relating to income derived by foreign corporations from the international operation of ships or aircraft. Those regulations

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations under section 402(a) of the Internal Revenue Code (Code) regarding the tax treatment of payments by qualified plans for medical or accident insurance. These regulations would affect administrators of, participants in, and beneficiaries of qualified retirement plans. This document also provides notice of

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9360) that were published in the Federal Register on Thursday, September 27, 2007 (72 FR 54820) providing certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of section 1291 of the Internal Revenue Code even though the foreign corporation in

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 a controlled group of corporations and consolidated groups filing lifenonlife Federal income tax returns. These temporary regulations provide guidance for calculating and apportioning between

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to notice of proposed rulemaking by crossreference to temporary regulations that was published in the Federal Register on Tuesday, December 19, 2006 (71 FR 75898) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final regulations (TD 9323) that were published in the Federal Register on Thursday, April 12, 2007 (72 FR 18386) 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

This document contains corrections to notice of proposed rulemaking that was published in the Federal Register on Tuesday, May 29, 2007 (72 FR 29456) providing mortality tables to be used in determining present value or making any computation for purposes of applying certain pension funding requirements.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains corrections to final and temporary regulations (TD 9339) that were published in the Federal Register on Monday, July 16, 2007 (72 FR 38767) providing guidance to state and local governments that issue qualified zone academy bonds and to banks, insurance companies, and other taxpayers that hold those bonds on the program

DEPARTMENT OF THE TREASURY : Internal Revenue Service

Elsewhere in this issue of the Federal Register, the IRS is issuing temporary regulations concerning information reporting on employerowned life insurance contracts under section 6039I of the Internal Revenue Code (Code). The temporary regulations generally apply to taxpayers that are engaged in a trade or business and that are directly or

DEPARTMENT OF THE TREASURY : Internal Revenue Service