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76. Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

PROPOSED RULES: Corporate reorganizations; additional distributions guidance; cross-reference,

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that amend Sec. 1.3682T(l), which provides 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 are issued
DEPARTMENT OF THE TREASURY : Internal Revenue Service

77. Qualified Films Under Section 199

PROPOSED RULES: Domestic production activities; attributable income deduction,

This document contains proposed amendments to the regulations involving the deduction for income attributable to domestic production activities under section 199. The proposed amendments affect taxpayers who produce qualified films under section 199(c)(4)(A)(i)(II) and (c)(6) and taxpayers who are members of an expanded affiliated group under section
DEPARTMENT OF THE TREASURY : Internal Revenue Service

78. Built-in Gains and Losses Under Section 382(h); Correction

RULES: Built-in gains and losses; Correction,

This document contains corrections to temporary regulations (TD 9330) that were published in the Federal Register on Thursday, June 14, 2007 (72 FR 32792) applying to corporations that have undergone ownership changes within the meaning of section 382. These regulations provide guidance regarding the treatment of prepaid income under the builtin
DEPARTMENT OF THE TREASURY : Internal Revenue Service

79. Employee Benefits - Cafeteria Plans

PROPOSED RULES: Employee benefits; cafeteria plans; Correction,

Correction

In proposed rule document E714827 beginning on page 43938 in the issue of Monday, August 6, 2007, make the following correction:

On page 43939, in the first column, the first heading:

I. New Proposed Sec. 1.1251Qualified and Nonqualified Benefits in Cafeteria Plans Section 125 Exclusive Noninclusion Rule
should be two separate

DEPARTMENT OF THE TREASURY : Internal Revenue Service

80. Notification Requirement for Tax-Exempt Entities Not Currently Required To File; Correction

RULES: Tax-exempt entities not currently required to file; notification requirement; Correction,

This document contains corrections 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

81. Anti-Avoidance and Anti-Loss Reimportation Rules Applicable Following a Loss on Disposition of Stock of Consolidated

PROPOSED RULES: Consolidated subsidiaries stock disposition loss; anti-avoidance and anti-loss reimportation rules; cross-reference,

In the Rules and Regulations section of this issue of the Federal
[[Page 17815]]
Register, the IRS is issuing temporary regulations under section 1502 of the Internal Revenue Code (Code). The temporary regulations provide guidance to corporations filing consolidated returns. The temporary regulations apply an antiavoidance rule and revise an
DEPARTMENT OF THE TREASURY : Internal Revenue Service

82. Guidance Necessary to Facilitate Business Electronic Filing and Burden Reduction; Correction

RULES: Business electronic filing and burden reduction; facilitation; correction,

This document contains a correction to final regulations (TD 9329) that were published in the Federal Register on Thursday, June 14, 2007 (72 FR 32794) affecting taxpayers that file Federal income tax returns. They simplify, clarify, or eliminate reporting burdens and also eliminate regulatory impediments to the electronic filing of certain
DEPARTMENT OF THE TREASURY : Internal Revenue Service

83. Partner's Distributive Share

PROPOSED RULES: Partner's distributive share,

This document contains regulations that provide rules concerning the application of sections 704(c)(1)(B) and 737 to distributions of property after two partnerships engage in an assets over merger. The proposed regulations affect partnerships and their partners. This document also provides a notice of public hearing on these proposed regulations.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

84. Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

RULES: Qualified zone academy bonds; obligations of States and political subdivisions; Correction,

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

85. Hybrid Retirement Plans

PROPOSED RULES: Hybrid retirement plans,

This document contains proposed regulations providing guidance relating to sections 411(a)(13) and 411(b)(5) of the Internal Revenue Code (Code) concerning certain hybrid defined benefit plans. These regulations provide guidance on changes made by the Pension Protection Act of 2006. These regulations affect sponsors, administrators, participants,
DEPARTMENT OF THE TREASURY : Internal Revenue Service

86. Guidance Necessary to Facilitate Business Electronic Filing Under Section 1561

RULES: Business electronic filing; guidance; correction,

Correction

In rule document 069758 beginning on page 76904 in the issue of Friday, December 22, 2006, make the following corrections:

Sec. 1.3421 [Corrected]

1. On page 76906, in the third column, in the section heading for Sec. 1.3421, ``Sec. 4.3421 [Removed]'' should read ``Sec. 1.3421 [Removed]''.

Sec. 1.5631T [Corrected]

2. On

DEPARTMENT OF THE TREASURY : Internal Revenue Service

87. Section 1367 Regarding Open Account Debt

PROPOSED RULES: Open account debt between S corporations and their shareholders; hearing; Correction,

Correction

In proposed rule document E76764 beginning on page 18417 in the issue of Thursday, April 12, 2007, make the following correction: Sec. 1.13672 [Corrected]

On page 18422, in Sec. 1.13672(e), in Example 7, in the table, in the last column, in the last entry, ``2,000'' should read ``$2,000''. [FR Doc. Z76764 Filed 5907; 8:45 am]

DEPARTMENT OF THE TREASURY : Internal Revenue Service

88. Section 1367 Regarding Open Account Debt; Correction

PROPOSED RULES: Open account debt between S corporations and their shareholders; hearing; Cancellation,

This document cancels a public hearing on proposed regulations under section 1367 of the Internal Revenue Code relating to the treatment of open account debt between S corporations and their shareholders.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

89. Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

RULES: Qualified zone academy bonds; obligations of States and political subdivisions; Correction,

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

90. Notification Requirement for Tax-Exempt Entities Not Currently Required to File

RULES: Tax-exempt entities not currently required to file; notification requirement,

This document contains temporary regulations 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 electronic notice including certain information required by section 6033(i)(1)(A) through (F). The text of the
DEPARTMENT OF THE TREASURY : Internal Revenue Service

91. Computer Software Under Section 199(c)(5)(B)

RULES: Computer software,

This document contains final regulations concerning the application of section 199 of the Internal Revenue Code, which provides a deduction for income attributable to domestic production activities. The final regulations are necessary to provide guidance regarding certain transactions involving online software and to clarify the rules regarding
DEPARTMENT OF THE TREASURY : Internal Revenue Service

92. Unified Rule for Loss on Subsidiary Stock; Correction

PROPOSED RULES: Unified rule for loss on subsidiary stock; Correction,

This document contains corrections to a notice of proposed rulemaking that were published in the Federal Register on Tuesday, January 23, 2007 (72 FR 2964). These regulations apply to corporations filing consolidated returns. The regulations implement aspects of the repeal of the General Utilities doctrine by redetermining members' bases in subsidiary
DEPARTMENT OF THE TREASURY : Internal Revenue Service

93. Built-in Gains and Losses Under Section 382(h); Correction

RULES: Built-in gains and losses; Correction,

This document contains a correction to temporary regulations (TD 9330) that were published in the Federal Register on Thursday, June 14, 2007 (72 FR 32792) applying to corporations that have undergone ownership changes within the meaning of section 382. These regulations provide guidance regarding the treatment of prepaid income under the builtin
DEPARTMENT OF THE TREASURY : Internal Revenue Service

94. Medical and Accident Insurance Benefits Under Qualified Plans; Correction

PROPOSED RULES: Medical and accident insurance benefits under qualified plans; tax treatment of payments; Correction,

This document contains corrections to notice of proposed rulemaking that was published in the Federal Register on Monday, August 20, 2007 (72 FR 46421), regarding the tax treatment of payments by qualified plans for medical or accident insurance.
DEPARTMENT OF THE TREASURY : Internal Revenue Service

95. Foreign Tax Credit: Notification of Foreign Tax Redeterminations; Correction

RULES: Foreign tax credit; foreign tax redeterminations notification; Correction,

This document contains a correction to temporary regulations (TD 9362) that were published in the Federal Register on Wednesday, November 7, 2007 (72 FR 62771) relating to a United States taxpayer's obligation under section 905(c) of the Internal Revenue Code to notify the IRS of a foreign tax redetermination, which is a change in the taxpayer's
DEPARTMENT OF THE TREASURY : Internal Revenue Service

96. Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign

RULES: Repeal of tax interest on nonresident alien individuals and foreign corporations received from certain portfolio debt investments,

This document contains final regulations under sections 871 and 881 of the Internal Revenue Code (Code) relating to the exclusion from gross income of portfolio interest paid to a nonresident alien individual or foreign corporation. These regulations clarify how the portfolio interest rules apply with respect to interest paid to a partnership (or
DEPARTMENT OF THE TREASURY : Internal Revenue Service

97. Information Returns Required with Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic

RULES: Foreign and foreign-owned domestic corporations; required information returns,

This document contains final regulations that provide guidance under sections 6038 and 6038A of the Internal Revenue Code (Code). The final regulations clarify the information required to be furnished regarding certain related party transactions of certain foreign corporations and certain foreignowned domestic corporations. The final regulations
DEPARTMENT OF THE TREASURY : Internal Revenue Service

98. 1545-BF01

RULES: Employee benefits; cafeteria plans; removed; Correction,


Employee Benefits Cafeteria Plans

Correction

In rule document E714823 appearing on page 41891 in the issue of Wednesday, August 1, 2007, make the following correction:

On page 41891, in the second column, under the SUMMARY heading, in the sixth line ``the < ='' should read ``the ''.
[FR Doc. Z714823 Filed 82307; 8:45 am]
BILLING CODE

DEPARTMENT OF THE TREASURY : Internal Revenue Service

99. Withholding Procedures Under Section 1441 for Certain Distributions to Which Section 302 Applies

PROPOSED RULES: Corporate stock distribution; withholding agent's obligation to withhold and report tax under Chapter 3,

This document contains proposed regulations regarding a withholding agent's obligation to withhold and report tax under Chapter 3 of the Internal Revenue Code when there is a distribution in redemption of stock of a corporation that is actively traded on an established financial market. Specifically, the proposed regulations provide an escrow
DEPARTMENT OF THE TREASURY : Internal Revenue Service

100. Nuclear Decommissioning Funds

PROPOSED RULES: Nuclear decommissioning funds,

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations under section 468A of the Internal Revenue Code relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants. The temporary regulations reflect changes to the law made by the Energy Policy
DEPARTMENT OF THE TREASURY : Internal Revenue Service

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