Department of the Treasury September 14, 2010 – Federal Register Recent Federal Regulation Documents

Series LLCs and Cell Companies
Document Number: 2010-22793
Type: Proposed Rule
Date: 2010-09-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations regarding the classification for Federal tax purposes of a series of a domestic series limited liability company (LLC), a cell of a domestic cell company, or a foreign series or cell that conducts an insurance business. The proposed regulations provide that, whether or not a series of a domestic series LLC, a cell of a domestic cell company, or a foreign series or cell that conducts an insurance business is a juridical person for local law purposes, for Federal tax purposes it is treated as an entity formed under local law. Classification of a series or cell that is treated as a separate entity for Federal tax purposes generally is determined under the same rules that govern the classification of other types of separate entities. The proposed regulations provide examples illustrating the application of the rule. The proposed regulations will affect domestic series LLCs; domestic cell companies; foreign series, or cells that conduct insurance businesses; and their owners.
Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations and Deferred Original Issue Discount Deductions; Correction
Document Number: 2010-22792
Type: Rule
Date: 2010-09-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains correcting amends to temporary regulations under section 108(i) of the Internal Revenue Code. These regulations primarily affect C corporations regarding the acceleration of deferred discharge of indebtedness (COD) income (deferred COD income) and deferred original issue discount (OID) deductions (deferred OID deductions) under section 108(i)(5)(D), and the calculation of earnings and profits as a result of an election under section 108(i). These errors were made when the agency published temporary regulations (TD 9497) in the Federal Register on Friday, August 13, 2010 (75 FR 49394).
Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations and Deferred Original Issue Discount Deductions; Correction
Document Number: 2010-22791
Type: Proposed Rule
Date: 2010-09-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-142800-09) that was published in the Federal Register on Friday, August 13, 2010 (75 FR 49428) primarily affecting C corporations regarding the acceleration of deferred discharge of indebtedness (COD) income (deferred COD income) and deferred original issue discount (OID) deductions (deferred OID deductions) under section 108(i)(5)(D), and the calculation of earnings and profits as a result of an election under section 108(i). In addition, these regulations provide rules applicable to all taxpayers regarding deferred OID deductions under section 108(i) as a result of a reacquisition of an applicable debt instrument by an issuer or related party.
Proposed Collection; Comment Request for Form 1097-BTC, Bond Tax Credit
Document Number: 2010-22790
Type: Notice
Date: 2010-09-14
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 1097-BTC, Bond Tax Credit.