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PROPOSED RULES: Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction, C8-01105; Capital Costs Incurred to Comply With EPA Sulfur Regulations,
Published: 2008-06-27
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing temporary regulations under
section 179B of the Internal Revenue Code (Code) relating to the
deduction for qualified capital costs paid or incurred by a small
business refiner to comply with the highway diesel fuel sulfur control
requirements of the
Part III: Treasury Department, Internal Revenue Service,
Published: 2008-08-20
This document contains proposed regulations under sections
367(a), 367(a)(5), 367(b), 1248(a), 1248(e), 1248(f), and 6038B of the
Internal Revenue Code (Code). The proposed regulations under sections
367(a)(5) and 367(b) apply when a domestic corporation transfers
certain property to a foreign corporation in an exchange described in
section 361(a)
PROPOSED RULES: Information Reporting for Discharges of Indebtedness,
Published: 2008-11-10
In the Rules and Regulations section of this issue of the
Federal Register, the IRS is issuing final and temporary regulations
relating to information returns for cancellation of indebtedness by
certain entities. The temporary regulations will avoid premature
information reporting from certain businesses that are currently
required to report and
PROPOSED RULES: Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Hearing Cancellation,
Published: 2008-03-28
This document cancels a public hearing on proposed regulations
that provide guidance relating to the reduction of the number of
separate foreign tax credit limitation categories under section 904(d)
of the Internal Revenue Code. Changes to the applicable law were made
by the American Jobs Creation Act of 2004 reducing the number of
section 904(d)
PROPOSED RULES: S Corporation Guidance Under AJCA of 2004 and GOZA of 2005; Hearing Cancellation,
Published: 2008-01-07
This document cancels a public hearing on proposed regulations
that provide guidance regarding certain changes made to the rules
governing S corporations under the American Jobs Creation Act of 2004
and the Gulf Opportunity Zone Act of 2005.
PROPOSED RULES: Reasonable Good Faith Interpretation of Required Minimum Distribution Rules by Governmental Plans,
Published: 2008-07-10
This document contains proposed regulations under sections
401(a)(9) and 403(b) of the Internal Revenue Code (Code) to permit a
governmental plan to comply with the required minimum distribution
rules by using a reasonable and good faith interpretation of the
statute. These proposed regulations will affect administrators of,
employers maintaining,
PROPOSED RULES: Declaratory Judgments - Gift Tax Determinations; Hearing Cancellation,
Published: 2008-09-29
This document cancels a public hearing on proposed regulations
under section 7477 of the Internal Revenue Code (Code) regarding
petitions filed with the United States Tax Court for declaratory
judgments as to the valuation of gifts.
PROPOSED RULES: Multiemployer Plan Funding Guidance,
Published: 2008-03-18
This document contains proposed regulations under section 432 [[Page 14418]]
of the Internal Revenue Code (Code). These proposed regulations provide
additional rules for certain multiemployer defined benefit plans that
are in effect on July 16, 2006. These proposed regulations affect
sponsors and administrators of, and participants in multiemployer
PROPOSED RULES: Guidance Regarding Foreign Base Company Sales Income; Hearing,
Published: 2008-06-09
This document provides notice of public hearing on proposed
regulations that provide guidance relating to foreign base company
sales income, as defined in section 954(d), in cases in which personal
property sold by a controlled foreign corporation (CFC) is
manufactured, produced, or constructed pursuant to a contract
manufacturing arrangement or
RULES: Converting an IRA Annuity to a Roth IRA,
Published: 2008-07-29
This document contains final regulations under section 408A of
the Internal Revenue Code (Code). These final regulations provide
guidance concerning the tax consequences of converting a nonRoth IRA
annuity to a Roth IRA. These final regulations affect individuals
establishing Roth IRAs, beneficiaries under Roth IRAs, and trustees,
custodians and
RULES: Section 1367 Regarding Open Account Debt,
Published: 2008-10-20
This document contains final regulations relating to the
treatment of open account debt between S corporations and their
shareholders. These final regulations provide rules regarding the
definition of open account debt and the adjustments in basis of any
indebtedness of an S corporation to a shareholder under section
1367(b)(2) of the Internal
PROPOSED RULES: Hybrid Retirement Plans; Correction,
Published: 2008-04-15
Correction
In proposed rule document E725025 beginning on page 73680 in the
issue of Friday, December 28, 2007, make the following corrections: Sec. 1.411(b)(5)1 [Corrected]
1. On page 73694, in the second column, in the second line, in
Sec. 1.411(b)(5)1(c)(4)(v)(A)(1), ``(1) General rule.'' should read ``(1) General rule.''.
2. On page
PROPOSED RULES: Consolidated Returns; Intercompany Obligations,
Published: 2008-02-25
This document withdraws a portion of a notice of proposed
rulemaking (REG10759200) published in the Federal Register on
September 28, 2007 (72 FR 55139). The withdrawn portion relates to the
treatment of transactions involving the provision of insurance between
members of a consolidated group.
PROPOSED RULES: Multiemployer Plan Funding Guidance; Hearing,
Published: 2008-06-27
This document provides notice of a public hearing on a notice
of proposed rulemaking providing additional rules for certain
multiemployer defined benefit plans that are in effect on July 16,
2006. These proposed regulations affect sponsors and administrators of,
and participants in multiemployer plans that are in either endangered
or critical
PROPOSED RULES: Regulations Enabling Elections for Certain Transactions under Section 336(e),
Published: 2008-08-25
This document contains proposed regulations under section
336(e) of the Internal Revenue Code. These proposed regulations, when
finalized, would permit taxpayers to make an election to treat certain
sales, exchanges, and distributions of another corporation's stock as
taxable sales of that corporation's assets. These proposed regulations
will
RULES: Information Reporting for Discharges of Indebtedness,
Published: 2008-11-10
This document contains final and temporary regulations
relating to information returns for cancellation of indebtedness by
certain entities. The temporary regulations will avoid premature
information reporting from certain businesses that are currently
required to report and will reduce the number of information returns
required to be filed. The
PROPOSED RULES: Treatment of Overall Foreign and Domestic Losses; Hearing Cancellation,
Published: 2008-03-28
This document cancels a public hearing on proposed rulemaking
by crossreference to temporary regulations providing guidance relating
to the recapture of overall foreign and domestic losses.
PROPOSED RULES: Diversification Requirements for Certain Defined Contribution Plans,
Published: 2008-01-03
This document contains proposed regulations under section
401(a)(35) of the Internal Revenue Code (Code) relating to
diversification requirements for certain defined contribution plans and
to publicly traded employer securities. These regulations will affect
administrators of, employers maintaining, participants in, and
beneficiaries of defined
RULES: REMIC Residual InterestsAccounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders),
Published: 2008-07-14
This document contains final regulations relating to income
that is associated with a residual interest in a Real Estate Mortgage
Investment Conduit (REMIC) and that is allocated through certain
entities to foreign persons who have invested in those entities. The
foreign persons covered by these regulations include partners in
domestic
PROPOSED RULES: Guidance Under Sections 642 and 643 (Income Ordering Rules); Hearing Cancellation,
Published: 2008-09-29
This document cancels a public hearing on proposed rulemaking
providing guidance under Internal Revenue 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
RULES: Abandonment of Stock or Other Securities,
Published: 2008-03-12
This document contains final regulations concerning the
availability and character of a loss deduction under section 165 of the
Internal Revenue Code (Code) for losses sustained from abandoned stock
or other securities. The final regulations clarify the tax treatment of
losses from abandoned securities, and affect any taxpayer claiming a
deduction
PROPOSED RULES: Qualified Nonpersonal Use Vehicles,
Published: 2008-06-09
This document contains proposed regulations relating to
qualified nonpersonal use vehicles as defined in section 274(i).
Qualified nonpersonal use vehicles are excepted from the substantiation
requirements of section 274(d)(4) that apply to listed property as
defined in section 280F(d)(4). These proposed regulations would add
clearly marked public
RULES: Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income; Correction,
Published: 2008-07-29
This document contains a correction to final and temporary
regulations (TD 9406) that was published in the Federal Register on
Thursday, July 3, 2008 (73 FR 38113) addressing the treatment of
certain income and assets related to the leasing of aircraft or vessels
in foreign commerce under sections 367, 954, and 956 of the Internal
Revenue Code.
RULES: Correcting Amendment,
Published: 2008-10-20
This document contains corrections to final regulations (TD
9424) that were published in the Federal Register on Wednesday,
September 17, 2008 (73 FR 53934) under sections 358, 362(e)(2), and
1502 of the Internal Revenue Code. The final regulations apply to
corporations filing consolidated returns, and corporations that enter
into certain taxfree
PROPOSED RULES: Amendment of Matching Rule for Certain Gains on Member Stock; Guidance; Correction,
Published: 2008-04-11
Correction
In proposed rule document E84571 beginning on page 12312 in the
issue of Friday, March 7, 2008, make the following corrections: Sec. 1.150213 [Corrected]
1. On page 12313, in the first column, in Sec. 1.1502
13(c)(6)(ii)(C)(1), in the fifth line, ``Register.'' should read ``Register].''.
2. On the same page, in the same