Department of Treasury March 7, 2008 – Federal Register Recent Federal Regulation Documents

Diversification Requirements for Variable Annuity, Endowment, and Life Insurance Contracts
Document Number: E8-4577
Type: Rule
Date: 2008-03-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations concerning the diversification requirements of section 817(h) of the Internal Revenue Code (Code). The regulations expand the list of holders whose beneficial interests in an investment company, partnership, or trust do not prevent a segregated asset account from looking through to the assets of the investment company, partnership, or trust, to satisfy the requirements of section 817(h). The regulations also remove the sentence in Sec. 1.817-5(a)(2) that provides that the payment required to remedy an inadvertent diversification failure must be based on the tax that would have been owed by the policyholders if they were treated as receiving the income on the contract. The regulations affect insurance companies that issue variable contracts and affect policyholders who purchase such contracts.
Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts
Document Number: E8-4576
Type: Proposed Rule
Date: 2008-03-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
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. The proposed regulations affect charitable remainder trusts that have UBTI in taxable years beginning after December 31, 2006. This document also provides notice of a public hearing on these proposed regulations.
Qualified Films Under Section 199
Document Number: E8-4575
Type: Rule
Date: 2008-03-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations involving the deduction for income attributable to domestic production activities under section 199. The final regulations revise certain rules and examples relating to the definitions of a qualified film produced by the taxpayer under section 199(c)(4)(A)(i)(II) and (c)(6) and an expanded affiliated group under section 199(d)(4). The final regulations affect taxpayers who produce qualified films and taxpayers who are members of expanded affiliated groups.
Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock
Document Number: E8-4573
Type: Rule
Date: 2008-03-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final and temporary regulations 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 excluded from gross income in certain member stock transactions. These regulations affect corporations filing consolidated returns. 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.
Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock
Document Number: E8-4571
Type: Proposed Rule
Date: 2008-03-07
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 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 corporations filing consolidated returns.
Art Advisory Panel-Notice of Closed Meeting
Document Number: E8-4447
Type: Notice
Date: 2008-03-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Closed meeting of the Art Advisory Panel will be held in Washington, D.C.