Department of the Treasury 2005 – Federal Register Recent Federal Regulation Documents

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Open Meeting of the Area 1 Taxpayer Advocacy Panel (Including the States of New York, Connecticut, Massachusetts, Rhode Island, New Hampshire, Vermont and Maine)
Document Number: E5-2650
Type: Notice
Date: 2005-05-25
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 1 Taxpayer Advocacy Panel will be conducted in Boston, Massachusetts. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign Corporations
Document Number: 05-10267
Type: Proposed Rule
Date: 2005-05-25
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed amendments to the regulations under section 367 relating to certain transfers of stock involving foreign corporations in transactions governed by section 304. Specifically, these proposed regulations provide that if, pursuant to section 304(a)(1), a U.S person is treated as transferring stock of a domestic or foreign corporation to a foreign corporation in exchange for stock of such foreign corporation in a transaction to which section 351(a) applies, such deemed section 351 exchange is not a transfer to a foreign corporation subject to section 367(a). These proposed regulations also provide that if, pursuant to section 304(a)(1), a foreign acquiring corporation is treated as acquiring the stock of a foreign acquired corporation in a transaction to which section 351(a) applies, such deemed section 351 acquisition is not an acquisition subject to section 367(b).
Advisory Group to the Internal Revenue Service; Tax Exempt and Government Entities Division (TE/GE); Meeting
Document Number: E5-2599
Type: Notice
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Advisory Committee on Tax Exempt and Government Entities (ACT) will hold a public meeting on Wednesday, June 8, 2005.
Cancelled Open Meeting of the Wage & Investment Reducing Taxpayer Burden (Notices) Issue Committee of the Taxpayer Advocacy Panel
Document Number: E5-2598
Type: Notice
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Wage & Investment Reducing Taxpayer Burden (Notices) Issue Committee of the Taxpayer Advocacy Panel (via teleconference) has been cancelled. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Proposed Collection; Comment Request for Regulation Project
Document Number: E5-2597
Type: Notice
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13(44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning an existing final regulation, PS-54-94 (TD 8668), Environmental Settlement FundsClassification (Section 301.7701-4).
Submission for OMB Review; Comment Request
Document Number: 05-10314
Type: Notice
Date: 2005-05-24
Agency: Department of the Treasury, Department of Treasury
Submission for OMB Review; Comment Request
Document Number: 05-10313
Type: Notice
Date: 2005-05-24
Agency: Department of the Treasury, Department of Treasury
05-10312
Document Number: 05-10312
Type: Notice
Date: 2005-05-24
Agency: Department of the Treasury, Submission for Omb Review; Comment Request, Department of Treasury
Credit for Increasing Research Activities
Document Number: 05-10247
Type: Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control. These temporary regulations reflect changes made to section 41 by the Revenue Reconciliation Act of 1989 (1989 Act), which introduced the current computational regime for the credit, and the Small Business Job Protection Act of 1996, which introduced the alternative incremental research credit. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.
Credit for Increasing Research Activities
Document Number: 05-10236
Type: Proposed Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations, including consolidated groups, or a group of trades or businesses under common control. The text of those regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations and withdraws the proposed regulations published in the Federal Register on July 29, 2003 (68 FR 44499).
New Markets Tax Credit Program
Document Number: 05-10223
Type: Proposed Rule
Date: 2005-05-24
Agency: Community Development Financial Institutions Fund, Department of Treasury, Department of the Treasury
This document provides advance notice of proposed rulemaking for the issuance of regulations relating to the New Markets Tax Credit (NMTC) Program as authorized by 26 U.S.C. 45D. This document invites comments from the public on certain issues regarding the designation of low-income communities for purposes of the NMTC Program. All materials submitted will be available for public inspection and copying.
Safe Harbor for Valuation Under Section 475
Document Number: 05-10167
Type: Proposed Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document sets forth an elective safe harbor for dealers in securities, dealers in commodities, and traders in securities and commodities that permits these taxpayers to make an election pursuant to which the values of positions reported on certain financial statements are the fair market values of those positions for purposes of section 475 of the Internal Revenue Code. This safe harbor attempts to reduce the compliance burden upon taxpayers and to improve the administrability of the valuation aspect of section 475 for the Internal Revenue Service. This document also provides a notice of a public hearing on these proposed regulations.
Attained Age of the Insured Under Section 7702
Document Number: 05-10166
Type: Proposed Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations explaining how to determine the attained age of an insured for purposes of testing whether a contract qualifies as a life insurance contract for Federal income tax purposes. This document also provides notice of a public hearing on these proposed regulations.
Partnership Equity for Services
Document Number: 05-10164
Type: Proposed Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document withdraws the remaining portion of the notice of proposed rulemaking published in the Federal Register on June 3, 1971 (36 FR 10787) and contains proposed regulations relating to the tax treatment of certain transfers of partnership equity in connection with the performance of services. The proposed regulations provide that the transfer of a partnership interest in connection with the performance of services is subject to section 83 of the Internal Revenue Code (Code) and provide rules for coordinating section 83 with partnership taxation principles. The proposed regulations also provide that no gain or loss is recognized by a partnership on the transfer or vesting of an interest in the transferring partnership in connection with the performance of services for the transferring partnership. This document also provides a notice of public hearing on these proposed regulations.
Dual Consolidated Loss Regulations
Document Number: 05-10160
Type: Proposed Rule
Date: 2005-05-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, such loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. The proposed regulations address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group.
Information Returns by Donees Relating to Qualified Intellectual Property Contributions
Document Number: 05-10229
Type: Rule
Date: 2005-05-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations that provide guidance for the filing of information returns by donees relating to qualified intellectual property contributions. These temporary regulations affect donees receiving net income from qualified intellectual property contributions made after June 3, 2004. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register.
Information Returns by Donees Relating to Qualified Intellectual Property Contributions
Document Number: 05-10228
Type: Proposed Rule
Date: 2005-05-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance for the filing of information returns by donees relating to qualified intellectual property contributions. The text of the temporary regulations published in the Rules and Regulations section of this issue of the Federal Register also serves as the text of these proposed regulations. The regulations affect donees receiving qualified intellectual property contributions after June 3, 2004.
Sale and Issue of Marketable Book-Entry Treasury Bills, Notes, and Bonds-Bidder Definitions
Document Number: 05-10218
Type: Rule
Date: 2005-05-23
Agency: Fiscal Service, Public Debt Bureau, Department of Treasury, Department of the Treasury
The Department of the Treasury (``Treasury,'' ``We,'' or ``Us'') is issuing in final form an amendment to 31 CFR part 356 (Uniform Offering Circular for the Sale and Issue of Marketable Book- Entry Treasury Bills, Notes, and Bonds) by modifying its definitions of different types of bidders in Treasury marketable securities auctions. This final amendment allows a certain business relationship between two entities that currently would be treated as a single bidder under the auction rules to be treated as separate bidders. Specifically, the amendment states that an entity that is more than 50-percent-owned by a corporation or partnership is not deemed to be an affiliate of the corporation or partnership if the ownership is for investment purposes only and certain other conditions are met. The amendment updates the auction rules to acknowledge a business practice that currently is not accommodated in the rules.
Government Securities Act Regulations: Custodial Holdings of Government Securities
Document Number: 05-10217
Type: Rule
Date: 2005-05-23
Agency: Department of the Treasury, Department of Treasury
The Department of the Treasury (``Treasury,'' ``We,'' or ``Us'') is issuing in final form an amendment to the regulations issued under the Government Securities Act of 1986, as amended (``GSA''), that are applicable to depository institutions that hold government securities as fiduciary, custodian, or otherwise for the account of customers. The provisions of the GSA regulations for custodial holding of government securities held by depository institutions generally provide an exemption from these rules for a depository institution's holdings of such government securities that are subject to the fiduciary standards of the Board of Governors of the Federal Reserve System (``the Board''), the Federal Deposit Insurance Corporation (``FDIC''), or the Office of the Comptroller of the Currency (``OCC''). We published a proposed rule amendment to the exemption on September 23, 2004, and are now adopting the change as proposed. Specifically, this amendment modifies the exemption to include savings associations subject to the fiduciary standards of the Office of Thrift Supervision (``OTS'').
Deemed Election To Be an Association Taxable as a Corporation for a Qualified Electing S Corporation
Document Number: 05-10165
Type: Rule
Date: 2005-05-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that deem certain eligible entities that file timely S corporation elections to have elected to be classified as associations taxable as corporations. These regulations affect certain eligible entities filing timely elections to be S corporations on or after July 20, 2004.
Mortgage Revenue Bonds
Document Number: 05-10163
Type: Rule
Date: 2005-05-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance regarding the limitation on the effective rate of mortgage interest for purposes of mortgage revenue bonds issued by State and local governments. These regulations provide guidance to State and local governments that issue tax-exempt mortgage revenue bonds.
Open Meeting of the Taxpayer Advocacy Panel Earned Income Tax Credit Issue Committee
Document Number: 05-10171
Type: Notice
Date: 2005-05-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Earned Income Tax Credit Issue Committee will be conducted (via teleconference). The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Low Income Taxpayer Clinic Grant Program; Availability of 2006 Grant Application Package
Document Number: 05-10170
Type: Notice
Date: 2005-05-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a notice that the IRS has made available the grant application package (Publication 3319) for organizations interested in applying for a Low Income Taxpayer Clinic (LITC) matching grant for the 2006 grant cycle (January 1, 2006, through December 31, 2006). The IRS will award a total of up to $6,000,000 (unless otherwise provided by specific Congressional appropriation) to qualifying organizations, subject to the limitations of Internal Revenue Code section 7526, for LITC matching grants.
Additional Rules for Exchanges of Personal Property Under Section 1031(a)
Document Number: 05-9960
Type: Rule
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that replace the use of the Standard Industrial Classification (SIC) system with the North American Industry Classification System (NAICS) for determining what properties are of a like class for purposes of section 1031 of the Internal Revenue Code (Code). The regulations affect taxpayers that engage in like-kind exchanges of depreciable tangible personal property.
Regulations Governing Practice Before the Internal Revenue Service
Document Number: 05-9959
Type: Rule
Date: 2005-05-19
Agency: Office of the Secretary, Department of the Treasury, Department of Treasury
This document contains final regulations revising the regulations governing practice before the Internal Revenue Service (Circular 230). These regulations affect individuals who practice before the Internal Revenue Service. These regulations clarify the standards for covered opinions.
Proposed Establishment of the Wahluke Slope Viticultural Area (2005R-026P)
Document Number: 05-10009
Type: Proposed Rule
Date: 2005-05-19
Agency: Alcohol and Tobacco Tax and Trade Bureau, Department of Treasury, Department of the Treasury
The Alcohol and Tobacco Tax and Trade Bureau proposes to establish the ``Wahluke Slope'' viticultural area in Grant County, in eastern Washington State. The proposed 81,000-acre area is totally within the established Columbia Valley viticultural area. We designate viticultural areas to allow vintners to better describe the origin of their wines and to allow consumers to better identify wines they may purchase. We invite comments on this proposed addition to our regulations.
Proposed Establishment of the San Antonio Valley Viticultural Area (2004R-599P)
Document Number: 05-10008
Type: Proposed Rule
Date: 2005-05-19
Agency: Alcohol and Tobacco Tax and Trade Bureau, Department of Treasury, Department of the Treasury
The Alcohol and Tobacco Tax and Trade Bureau proposes to establish the ``San Antonio Valley'' viticultural area in southwest Monterey County, California, within the existing Central Coast viticultural area. We designate viticultural areas to allow vintners to better describe the origin of their wines and allow consumers to better identify wines they may purchase. We invite comments on this proposed addition to our regulations.
Proposed Expansion of San Francisco Bay and Central Coast Viticultural Areas (2002R-202P)
Document Number: 05-10007
Type: Proposed Rule
Date: 2005-05-19
Agency: Alcohol and Tobacco Tax and Trade Bureau, Department of Treasury, Department of the Treasury
The Alcohol and Tobacco Tax and Trade Bureau proposes to amend its regulations to expand by approximately 20,000 acres the San Francisco Bay viticultural area and the Central Coast viticultural area in California to match the proposed boundary of an expanded Livermore Valley viticultural area. We designate viticultural areas to allow bottlers to better describe the origin of wines and allow consumers to better identify the wines they may purchase. We invite comments on this proposed amendment to our regulations.
Proposed Expansion of the Livermore Valley Viticultural Area (2002R-202P)
Document Number: 05-10006
Type: Proposed Rule
Date: 2005-05-19
Agency: Alcohol and Tobacco Tax and Trade Bureau, Department of Treasury, Department of the Treasury
The Alcohol and Tobacco Tax and Trade Bureau proposes to amend its regulations to expand the existing 96,000-acre Livermore Valley viticultural area in Alameda County, California. The proposed expansion would add 163,000 acres to the Livermore Valley viticultural area in northern Alameda and southern Contra Costa Counties. We designate viticultural areas to allow vintners to better describe the origin of their wines and to allow consumers to better identify the wines they may purchase. We invite comments on this proposed addition to our regulations.
Proposed Information Collection; Comment Request
Document Number: 05-10005
Type: Notice
Date: 2005-05-19
Agency: Alcohol and Tobacco Tax and Trade Bureau, Department of Treasury, Department of the Treasury
As part of our continuing effort to reduce paperwork and respondent burden, and as required by the Paperwork Reduction Act of 1995, we invite comments on the proposed or continuing information collections listed below in this notice.
Proposed Collection; Comment Request for Form 8697
Document Number: E5-2498
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8697, Interest Computation Under the Look-Back Method for Completed Long-Term Contracts.
Proposed Collection; Comment Request for Form 8840
Document Number: E5-2497
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8840, Closer Connection Exception Statement for Aliens.
Proposed Collection; Comment Request for Revenue Procedures 2002-37, 2002-38, and 2002-39
Document Number: E5-2496
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedures 2002-37, 2002-38, 2002-39, Changes in Periods of Accounting.
Proposed Collection; Comment Request for Revenue Procedure 2005-24
Document Number: E5-2495
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2005-24, Waiver of Spousal Election.
Proposed Collection; Comment Request for Form 8814
Document Number: E5-2494
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8814, Parents' Election To Report Child's Interest and Dividends.
Proposed Collection; Comment Request for Form 8896
Document Number: E5-2493
Type: Notice
Date: 2005-05-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8896, Low Sulfur Diesel Fuel Production Credit.
Proposed Collection; Comment Request for Form 8801
Document Number: E5-2486
Type: Notice
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 8801, Credit For Prior Year Minimum TaxIndividuals, Estates and Trusts.
Proposed Collection; Comment Request for Form 1099-A
Document Number: E5-2485
Type: Notice
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Form 1099-A, Acquisition or Abandonment of Secured Property.
Proposed Collection; Comment Request for Revenue Procedure 2005-XX
Document Number: E5-2484
Type: Notice
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2005-XX, Limit of Retroactive Application.
Proposed Collection; Comment Request for Regulation Project
Document Number: E5-2483
Type: Notice
Date: 2005-05-18
Agency: Department of the Treasury, Internal Revenue Service, Department of Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning existing final regulation, REG-108524-00, Section 1446 Regulations.
Proposed Collection; Comment Request for Revenue Procedure 101177-05
Document Number: E5-2482
Type: Notice
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Public Law 104-13(44 U.S.C. 3506(c)(2)(A)). Currently, the IRS is soliciting comments concerning Revenue Procedure 2005-XX, Revenue Procedure Regarding Extended Period of Limitation for Listed Transaction Situations.
Submission for OMB Review; Comment Request
Document Number: 05-9890
Type: Notice
Date: 2005-05-18
Agency: Department of the Treasury, Department of Treasury
Submission for OMB Review; Comment Request
Document Number: 05-9889
Type: Notice
Date: 2005-05-18
Agency: Department of the Treasury, Department of Treasury
Section 1446 Regulations; Withholding on Effectively-Connected Taxable Income Allocable to Foreign Partners
Document Number: 05-9424
Type: Rule
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations regarding a partnership's obligation to pay withholding tax under section 1446 on effectively connected taxable income allocable under section 704 to a foreign partner. The regulations interpret the rules added to the Internal Revenue Code by section 1246(a) of the Tax Reform Act of 1986 (1986 Act), as amended by section 1012(s)(1)(A) of the Technical and Miscellaneous Revenue Act of 1988 (1988 Act), and section 7811(i)(6) of the Omnibus Budget Reconciliation Act of 1989 (1989 Act). The regulations will affect partnerships engaged in a trade or business in the United States that have one or more foreign partners. The final regulations also include conforming amendments to sections 871, 1443, 1461, 1462, 1463, 6109, and 6721. This document also contains temporary regulations under section 1446 that may apply to reduce or eliminate a partnership's obligation to pay withholding tax in certain circumstances.
Section 1446 Regulations; Withholding on Effectively-Connected Taxable Income Allocable to Foreign Partners
Document Number: 05-9423
Type: Proposed Rule
Date: 2005-05-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The IRS is proposing to issue regulations under section 1446 of the Internal Revenue Code relating to the circumstances under which a partnership may take partner-level deductions and losses into account in computing its withholding tax obligation with respect to a foreign partner's allocable share of effectively connected taxable income. The text of the temporary regulations published elsewhere in this issue of the Federal Register also serves as the text of these proposed regulations. In addition, the proposed regulations amend regulations under sections 1464, 6071, 6091, 6151, 6302, 6402, 6414, and 6722 to implement the section 1446 regime. This document also provides a notice of public hearing on these proposed regulations.
Guidance Under Section 355(e); Recognition of Gain on Certain Distributions of Stock or Securities in Connection With an Acquisition; Correction
Document Number: 05-9615
Type: Rule
Date: 2005-05-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document corrects final regulations and removal of temporary regulations (TD 9198), that were published in the Federal Register on Tuesday, April 19, 2005 (70 FR 20279) that relate to the recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition.
Statutory Mergers and Consolidations; Revision of Income Tax Regulations Under Sections 358, 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations; Hearing Cancellation
Document Number: 05-9612
Type: Proposed Rule
Date: 2005-05-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document provides notice of cancellation of a public hearing on proposed rulemaking that affects corporations engaging in mergers and consolidations and their shareholders under sections 358, 368(a)(1)(A), 367 and 884 of the Internal Revenue Code.
Withholding Exemptions: Correction
Document Number: 05-9611
Type: Proposed Rule
Date: 2005-05-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document corrects a notice of proposed rulemaking by cross-reference to temporary regulations that was published in the Federal Register on Thursday, April 14, 2005 (70 FR 19721). The document contains temporary regulations providing guidance under section 3402(f) of the Internal Revenue Code (Code) for employers and employees relating to the Form W-4, ``Employee's Withholding Allowance Certificate.''
Withholding Exemptions: Correction
Document Number: 05-9610
Type: Rule
Date: 2005-05-17
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document corrects final and temporary regulations (TD 9196) that were published in the Federal Register on Thursday, April 14, 2005 (70 FR 19694). The document contains regulations providing guidance under section 3402(f) of the Internal Revenue Code (Code) for employers and employees relating to the Form W-4, ``Employee's Withholding Allowance Certificate.''
Public Meeting of the President's Advisory Panel on Federal Tax Reform
Document Number: 05-9786
Type: Notice
Date: 2005-05-16
Agency: Department of the Treasury, Department of Treasury
This notice advises all interested persons of the location of the May 17, 2005, public meeting of the President's Advisory Panel on Federal Tax Reform. This meeting was previously announced in 70 FR 22758 (May 2, 2005).
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