In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the subpart F treatment of aircraft and vessel leasing income under sections 954 and 956 of the Internal Revenue Code (Code) and the transfer of tangible property incorporated in aircraft and vessels that are used

DEPARTMENT OF THE TREASURY : Internal Revenue Service

CFR Correction

In Title 26 of the Code of Federal Regulations, Part 1 (Sec. 1.1551 to End), revised as of April 1, 2007, on page 439, in Sec. 1.66542, in the undesignated paragraph following paragraph (d)(2)(ii)(B), make the following changes:

1. In the first sentence, after the word ``attributable'', insert the words ``to months in such

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) where partners are lookthrough entities or members of a consolidated group. The final regulations clarify the application of section 704(b) to partnerships the interests of which are

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9391) that were published in the Federal Register on Wednesday, April 9, 2008 (73 FR 19350) providing rules under section 937(b) of the Internal Revenue Code for determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1)

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of public hearing on a notice of proposed rulemaking preparing guidance on the determination of plan assets and benefit liabilities for purposes of the funding requirements that apply to single employer defined benefit plans.

These regulations affect sponsors, administrators, participants, and beneficiaries of

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 treatment of certain intercompany gains with respect to member stock within a consolidated group. The text of those regulations also serves as the text of these proposed regulations. These regulations affect

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations providing guidance on the application of the accrual rule for defined benefit plans under section 411(b)(1)(B) of the Internal Revenue Code (Code) in cases where plan benefits are determined on the basis of the greatest of two or more separate formulas. These regulations would affect sponsors,

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded from gross income under section 108(a). In particular, the regulations address situations in

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations (TD 9383) that were published in the Federal Register on Friday, March 7, 2008 (73 FR 12265). Concerning the treatment of certain intercompany gain with respect to consolidated group member stock. These amendments provide for the redetermination of an intercompany gain as

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document invites comments from the public regarding rules under section 529 of the Internal Revenue Code (Code) that the IRS and the Treasury Department expect to propose in a notice of proposed rulemaking. The rules focus mainly on the transfer tax provisions applicable to accounts (section 529 accounts) in Qualified Tuition Programs (QTPs).

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations relating to elections to deduct startup expenditures under section 195 of the Internal Revenue Code (Code), organizational expenditures of corporations under section 248, and organizational expenses of partnerships under section 709. The American Jobs Creation Act of 2004 amended these three

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final regulations (TD 9377) that were published in the Federal Register on Wednesday, January 23, 2008 (73 FR 3868), that apply to a section 197 intangible resulting from an assumption reinsurance transaction, and under section 338 that apply to reserve increases after a deemed asset sale.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

These proposed regulations under section 704(c) of the Internal Revenue Code (Code) provide that the section 704(c) antiabuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners. The proposed regulations further provide that a section 704(c) allocation method

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final and temporary regulations under section 1301 of the Internal Revenue Code (Code) relating to the averaging of farm and fishing income in computing income tax liability. The regulations reflect changes to the law made by the American Jobs Creation Act of 2004. The regulations provide guidance to individuals engaged in a

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document provides notice of public hearing on proposed regulations relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed regulations that provide guidance under Internal Revenue Code (Code) section 664 on the tax effect of unrelated business taxable income (UBTI) on charitable remainder trusts. The proposed regulations reflect the changes made to section 664(c) by section 424(a) and (b) of the Tax Relief and Health Care Act of 2006.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains proposed amendments providing guidance under Internal Revenue Code (Code) section 642(c) with regard to the Federal tax consequences of an ordering provision in a trust, a will, or a provision of local law that attempts to determine the tax character of the amounts paid to a charitable beneficiary of the trust or estate. The

DEPARTMENT OF THE TREASURY : Internal Revenue Service

These proposed regulations provide guidance concerning substantiation and reporting requirements for cash and noncash charitable contributions under section 170 of the Internal Revenue Code (Code). The regulations reflect the enactment of provisions of the American Jobs Creation Act of 2004 and
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the Pension Protection Act of 2006. The

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains a correction to final and temporary regulations (TD 9383) that were published in the Federal Register on Friday, March 7, 2008 (73 FR 12265).

Concerning the treatment of certain intercompany gain with respect to consolidated group member stock. These amendments provide for the redetermination of an intercompany gain as

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document contains final regulations under section 1502 of the Internal Revenue Code that provide guidance regarding the manner in which the items (including items described in section 381(c) but excluding intercompany items under Sec. 1.150213) of a liquidating corporation are succeeded to and taken into account in cases in which multiple

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 relating to the elections to deduct startup expenditures under section 195 of the Internal Revenue Code (Code), organizational expenditures of corporations under section 248, and organizational expenses of partnerships under section

DEPARTMENT OF THE TREASURY : Internal Revenue Service

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

This document contains final regulations under section 7874 of the Internal Revenue Code (Code) relating to the disregard of certain affiliateowned stock in determining whether a corporation is a surrogate foreign corporation under section 7874(a)(2)(B) of the Code.

DEPARTMENT OF THE TREASURY : Internal Revenue Service

In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing final and temporary regulations under section 1301 of the Internal Revenue Code (Code) relating to the averaging of farm and fishing income in computing income tax liability. The regulations reflect changes to the law made by the American Jobs Creation

DEPARTMENT OF THE TREASURY : Internal Revenue Service

This document withdraws a notice of proposed rulemaking relating to the circumstances in which accounts or notes receivable are ``acquired * * * for services rendered'' within the meaning of section 1221(a)(4).

DEPARTMENT OF THE TREASURY : Internal Revenue Service