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PROPOSED RULES: Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income,
Published: 2008-07-03
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
RULES: CFR Correction,
Published: 2008-03-19
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
RULES: Partners Distributive Share,
Published: 2008-05-19
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
RULES: Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction,
Published: 2008-07-18
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)
PROPOSED RULES: Measurement of Assets and Liabilities for Pension Funding Purposes; Hearing,
Published: 2008-04-23
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
PROPOSED RULES: Amendment of Matching Rule for Certain Gains on Member Stock; Guidance under Section 1502,
Published: 2008-03-07
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
PROPOSED RULES: Accrual Rules for Defined Benefit Plans,
Published: 2008-06-18
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,
PROPOSED RULES: Section 108 Reduction of Tax Attributes for S Corporations,
Published: 2008-08-06
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
RULES: Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction,
Published: 2008-04-03
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
PROPOSED RULES: Guidance on Qualified Tuition Programs Under Section 529,
Published: 2008-01-18
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).
RULES: Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures and Partnership Organizational Expenses,
Published: 2008-07-08
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
RULES: Application of Section 338 to Insurance Companies; Correction,
Published: 2008-03-18
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.
PROPOSED RULES: Contributed Property,
Published: 2008-05-19
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
RULES: Farmer and Fisherman Income Averaging,
Published: 2008-07-22
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
PROPOSED RULES: Nuclear Decommissioning Funds; Hearing,
Published: 2008-04-23
This document provides notice of public hearing on proposed
regulations relating to deductions for contributions to trusts
maintained for decommissioning nuclear power plants.
PROPOSED RULES: Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts; Guidance Under Section 664,
Published: 2008-03-07
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.
PROPOSED RULES: Guidance Under Sections 642 and 643 (Income Ordering Rules),
Published: 2008-06-18
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
PROPOSED RULES: Agency Information Collection Activities; Proposals, Submissions, and Approvals: ; Loss Mitigation Evaluation, E8–17959 [ This table of contents entry was inadvertently ommitted from the Wednesday, August 6, 2008 edition of the . For the convenience of the reader, this entry is being published in today's edition of the . Please refer to page 45777 of the August 6, 2008 publication for the actual document and its contents.] ; Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions,
Published: 2008-08-07
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
[[Page 45909]]
the Pension Protection Act of 2006. The
RULES: Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction,
Published: 2008-04-03
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
RULES: Guidance Under Section 1502; Succession to Items of Liquidating Corp.,
Published: 2008-01-15
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
PROPOSED RULES: Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures and Partnership Organizational Expenses,
Published: 2008-07-08
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
RULES: Stock Transfer Rules; Carryover of Earnings and Taxes; Correction,
Published: 2008-03-18
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
RULES: Guidance Under Section 7874 for Determining the Ownership Percentage in the Case of Expanded Affiliated Groups,
Published: 2008-05-20
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.
PROPOSED RULES: Farmer and Fisherman Income Averaging,
Published: 2008-07-22
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
PROPOSED RULES: Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable,
Published: 2008-04-23
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).