Internal Revenue Service – Federal Register Recent Federal Regulation Documents

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Open Meeting of the Area 7 Taxpayer Advocacy Panel (Including the States of Alaska, California, Hawaii, and Nevada)
Document Number: E9-1274
Type: Notice
Date: 2009-01-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 7 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Earned Income Tax Credit Issue Committee.
Document Number: E9-1272
Type: Notice
Date: 2009-01-23
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. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel
Document Number: E9-1271
Type: Notice
Date: 2009-01-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel (TAP) is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Small Business/Self Employed Issue Committee of the Taxpayer Advocacy Panel
Document Number: E9-1270
Type: Notice
Date: 2009-01-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Small Business/Self Employed Issue Committee of the Taxpayer Advocacy Panel will be conducted (via teleconference). The Taxpayer Advocacy Panel (TAP) is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Volunteer Income Tax Assistance (VITA) Issue Committee
Document Number: E9-1269
Type: Notice
Date: 2009-01-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel VITA Issue Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Document Number: E9-1120
Type: Rule
Date: 2009-01-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final and temporary regulations (TD 9435) that were published in the Federal Register on Monday, December 15, 2008 (73 FR 75946) providing guidance regarding the distribution of stock of a controlled corporation acquired in a transaction described in section 355(a)(3)(B) of the Internal Revenue Code. This action is necessary in light of amendments to section 355(b). These temporary regulations will affect corporations and their shareholders. 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 Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Document Number: E9-1109
Type: Rule
Date: 2009-01-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final and temporary regulations (TD 9435) that were published in the Federal Register on Monday, December 15, 2008 (73 FR 75946) providing guidance regarding the distribution of stock of a controlled corporation acquired in a transaction described in section 355(a)(3)(B) of the Internal Revenue Code. This action is necessary in light of amendments to section 355(b). These temporary regulations will affect corporations and their shareholders.
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Document Number: E9-1104
Type: Proposed Rule
Date: 2009-01-21
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-150670-07) that was published in the Federal Register on Monday, December 15, 2008 (73 FR 75979) giving guidance regarding the distribution of stock of a controlled corporation acquired in a transaction described in section 355(a)(3)(B) of the Internal Revenue Code. This action is necessary in light of amendments to section 355(b). The text of those regulations also serves as the text of these proposed regulations. These regulations will affect corporations and their shareholders.
Section 707 Regarding Disguised Sales, Generally
Document Number: E9-1101
Type: Proposed Rule
Date: 2009-01-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document withdraws proposed regulations relating to the treatment of transactions between a partnership and its partners as disguised sales of partnership interests between the partners under section 707(a)(2)(B) of the Internal Revenue Code. The withdrawal affects partnerships and their partners.
The Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities
Document Number: E9-1100
Type: Proposed Rule
Date: 2009-01-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations under sections 301, 302, 304, 351, 354, 356, 358, 368, 861, 1001, and 1016 of the Internal Revenue Code (Code). The proposed regulations provide guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies, as well as guidance regarding the determination of gain and the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions. The proposed regulations affect shareholders and security holders of corporations. These proposed regulations are necessary to provide such shareholders and security holders with guidance regarding the allocation and recovery of basis on distributions of property.
Employer's Annual Federal Tax Return and Modifications to the Deposit Rules; Correction
Document Number: E9-1097
Type: Rule
Date: 2009-01-21
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final and temporary regulations (TD 9440) that were published in the Federal Register on Monday, December 29, 2008, relating to the annual filing of Federal employment tax returns and requirements for employment tax deposits. These temporary regulations relate to sections 6011 and 6302 of the Internal Revenue Code concerning reporting and paying income taxes withheld from wages and reporting and paying taxes under the Federal Insurance Contributions Act (FICA) (collectively, ``employment taxes'').
Highway Use Tax; Sold Vehicles and Electronic Filing
Document Number: E9-857
Type: Proposed Rule
Date: 2009-01-16
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance on mandatory electronic filing of Form 2290, ``Heavy Highway Vehicle Use Tax Return,'' for 25 or more vehicles; credits or refunds for sold, destroyed or stolen vehicles; and paying tax on the use of certain second-hand vehicles. The regulations reflect changes to the law made by the American Jobs Creation Act of 2004. The regulations would affect owners and operators of highway motor vehicles with a taxable gross weight of 55,000 pounds or more.
Proposed Collection; Comment Request for REG-110311-98 (Final)
Document Number: E9-770
Type: Notice
Date: 2009-01-15
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 REG-110311-98 (Final), Corporate Tax Shelter Registration.
Postponement of Certain Tax-Related Deadlines by Reason of a Federally Declared Disaster or Terroristic or Military Action
Document Number: E9-767
Type: Rule
Date: 2009-01-15
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to postponement of certain tax-related deadlines either due to service in a combat zone or due to a federally declared disaster. The regulations reflect changes in the law made by the Victims of Terrorism Tax Relief Act of 2001, the Tax Extenders and Alternative Minimum Tax Relief Act of 2008 (TEAMTRA), and current IRS practice. The regulations affect taxpayers serving in a combat zone and taxpayers affected by a federally declared disaster.
Proposed Collection; Comment Request for Form 3949-A
Document Number: E9-764
Type: Notice
Date: 2009-01-15
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 3949-A, Information Referral.
Proposed Collection; Comment Request for Form 13704
Document Number: E9-763
Type: Notice
Date: 2009-01-15
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 13704, Health Coverage Tax Credit Registration Update Form.
Proposed Collection; Comment Request For Regulation Project
Document Number: E9-761
Type: Notice
Date: 2009-01-15
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 regulations, FI-27-89 (TD 8366), Real Estate Mortgage Conduits; Reporting Requirements and Other Administrative Matters, and FI-61-91 (TD 8431), Allocation of Allocable Investment Expense; Original Issue Discount Reporting Requirements (Sec. Sec. 1.67-3, 1.860D-4, 1.860F-4, 1.6049-4 and 1.6049-7).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-760
Type: Notice
Date: 2009-01-15
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, FI-81-86 (TD 8513), Bad Debt reserves of Banks (Sec. 1.585-8).
Open Season for Membership to the Electronic Tax Administration Advisory Committee (ETAAC)
Document Number: E9-759
Type: Notice
Date: 2009-01-15
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Electronic Tax Administration Advisory Committee (ETAAC) was established to provide continued input into the development and implementation of the Internal Revenue Service (IRS) strategy for electronic tax administration. The ETAAC provides an organized public forum for discussion of electronic tax administration issues in support of the overriding goal that paperless filing should be the preferred and most convenient method of filing tax and information returns. ETAAC members convey the public's perception of IRS electronic tax administration activities, offer constructive observations about current or proposed policies, programs, and procedures, and suggest improvements. This document seeks applicants for selection as Committee members. The Director, Electronic Tax Administration (ETA) and Refundable Credits will assure that the size and organizational representation of the ETAAC obtains balanced membership and includes representatives from various groups including: (1) Tax practitioners and preparers, (2) transmitters of electronic returns, (3) tax software developers, (4) large and small business, (5) employers and payroll service providers, (6) individual taxpayers, (7) financial industry (payers, payment options and best practices), (8) system integrators (technology providers), (9) academic (marketing, sales or technical perspectives), (10) trusts and estates, (11) tax exempt organizations, and (12) state and local governments. We are soliciting applicants from professional and public interest groups. Members serve a three-year term on the ETAAC to allow for a rotation in membership which ensures that different perspectives are represented. All travel expenses within government guidelines will be reimbursed. Potential candidates must pass an IRS tax compliance check and Federal Bureau of Investigation (FBI) background investigation.
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-756
Type: Notice
Date: 2009-01-15
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 notice of proposed rulemaking, REG-209040-88, Qualified Electing Fund Elections (Sec. 1.1295).
Proposed Collection; Comment Request for Form 4810
Document Number: E9-754
Type: Notice
Date: 2009-01-15
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 4810, Request for Prompt Assessment Under Internal Revenue Code Section 6501(d).
Open Meeting of the Area 5 Taxpayer Advocacy Panel (Including the States of Iowa, Kansas, Minnesota, Missouri, Nebraska, Oklahoma, and Texas)
Document Number: E9-171
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 5 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Area 4 Taxpayer Advocacy Panel (Including the States of Illinois, Indiana, Kentucky, Michigan, Ohio, Tennessee, and Wisconsin)
Document Number: E9-170
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 4 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Small Business/Self Employed Issue Committee of the Taxpayer Advocacy Panel
Document Number: E9-168
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Small Business/Self Employed Issue Committee of the Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel (TAP) is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Volunteer Income Tax Assistance (VITA) Issue Committee
Document Number: E9-167
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel VITA Issue Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel
Document Number: E9-166
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Assistance Center Committee of the Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel (TAP) is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Language Services Issue Committee
Document Number: E9-164
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Language Services Issue Committee will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Joint Committee of the Taxpayer Advocacy Panel
Document Number: E9-162
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Joint Committee of the Taxpayer Advocacy Panel will be conducted via conference call. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Area 6 Taxpayer Advocacy Panel (Including the States of Arizona, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming)
Document Number: E9-153
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 6 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open meeting of the Area 7 Taxpayer Advocacy Panel (including the States of Alaska, California, Hawaii, and Nevada )
Document Number: E9-152
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 7 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Forms and Publications Issue Committee of the Taxpayer Advocacy Panel
Document Number: E9-150
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the IRS Forms and Publications Issue Committee of the Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Taxpayer Advocacy Panel Earned Income Tax Credit Issue Committee
Document Number: E9-149
Type: Notice
Date: 2009-01-09
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. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Wage & Investment Reducing Taxpayer Burden (Notices) Issue Committee of the Taxpayer Advocacy Panel
Document Number: E9-147
Type: Notice
Date: 2009-01-09
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 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.
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: E9-146
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 1 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Area 2 Taxpayer Advocacy Panel (Including the States of Delaware, North Carolina, South Carolina, New Jersey, Maryland, Pennsylvania, Virginia, West Virginia and the District of Columbia)
Document Number: E9-145
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 2 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Open Meeting of the Area 3 Taxpayer Advocacy Panel (Including the States of Florida, Georgia, Alabama, Mississippi, Louisiana, Arkansas, and the Territory of Puerto Rico)
Document Number: E9-144
Type: Notice
Date: 2009-01-09
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Area 3 Taxpayer Advocacy Panel will be conducted. The Taxpayer Advocacy Panel is soliciting public comment, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Withholding Under Internal Revenue Code Section 3402(t); Correction
Document Number: E9-85
Type: Proposed Rule
Date: 2009-01-08
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to a notice of proposed rulemaking (REG-158747-06) that was published in the Federal Register on Friday, December 5, 2008 (73 FR 74082) relating to withholding under section 3402(t) of the Internal Revenue Code. The proposed regulations reflect changes in the law made by the Tax Increase Prevention and Reconciliation Act of 2005 that require Federal, State, and local government entities to withhold income tax when making payments to persons providing property or services. These proposed regulations provide guidance to assist the government entities in complying with section 3402(t). The regulations also provide certain guidance to persons receiving payments for property or services from government entities.
Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement
Document Number: E8-30715
Type: Rule
Date: 2009-01-05
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations that provide further guidance and clarification regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations. The temporary regulations affect domestic and foreign entities that enter into cost sharing arrangements described in the temporary regulations. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register.
Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement
Document Number: E8-30712
Type: Proposed Rule
Date: 2009-01-05
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 that provide further guidance and clarification regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations. These temporary regulations potentially affect controlled taxpayers within the meaning of section 482 that enter into cost sharing arrangements as defined therein. The text of those temporary regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on those proposed regulations.
Guidance Regarding Foreign Base Company Sales Income
Document Number: E8-30729
Type: Proposed Rule
Date: 2008-12-29
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 and Treasury Department are issuing temporary regulations relating to foreign base company sales income, 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 by one or more branches of the CFC. The temporary regulations modify the foreign base company sales income regulations to address current business structures and practices, particularly the growing importance of contract manufacturing and other manufacturing arrangements. The temporary regulations, in general, will affect CFCs and their United States shareholders. The text of the temporary regulations also serves as the text of the proposed regulations. This document also provides notice of a public hearing.
Guidance Regarding Foreign Base Company Sales Income
Document Number: E8-30727
Type: Rule
Date: 2008-12-29
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final and temporary regulations that provide guidance relating to foreign base company sales income in cases in which personal property sold by a controlled foreign corporation is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the controlled foreign corporation. These regulations modify the foreign base company sales income regulations to address current business structures and practices, particularly the growing importance of contract manufacturing and other manufacturing arrangements. These regulations, in general, will affect controlled foreign corporations and their United States shareholders. 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.
Consolidated Returns; Intercompany Obligations
Document Number: E8-30718
Type: Rule
Date: 2008-12-29
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under section 1502 of the Internal Revenue Code (Code). The regulations provide guidance regarding the treatment of transactions involving obligations between members of a consolidated group. These final regulations will affect affiliated groups of corporations filing consolidated returns.
Disclosure of Return Information to the Bureau of Economic Analysis
Document Number: E8-30599
Type: Rule
Date: 2008-12-29
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to disclosures of corporate tax return information to the Bureau of Economic Analysis (Bureau). The final regulations authorize the IRS to disclose certain items of corporate tax return information to the Secretary of Commerce for purposes of structuring United States national economic accounts and conducting related statistical activities authorized by law. The final regulations facilitate the assistance of the IRS to the Bureau in its statistics programs, require no action by taxpayers, and have no effect on their tax liabilities.
Employer's Annual Federal Tax Return and Modifications to the Deposit Rules
Document Number: E8-30592
Type: Proposed Rule
Date: 2008-12-29
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document revises the notice of proposed rulemaking published in the Federal Register on January 3, 2006. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the annual filing of Federal employment tax returns and requirements for employment tax deposits under sections 6011 and 6302 of the Internal Revenue Code (Code). Those temporary regulations generally allow certain employers to file a Form 944, ``Employer's ANNUAL Federal Tax Return,'' rather than Form 941, ``Employer's QUARTERLY Federal Tax Return.'' In addition to rules related to Form 944, those temporary regulations provide an additional method for employers who file Form 941 to determine whether the amount of accumulated employment taxes is considered de minimis. The temporary and proposed regulations affect taxpayers that file Form 941, ``Employer's QUARTERLY Federal Tax Return,'' Form 944, ``Employer's ANNUAL Federal Tax Return,'' and any related Spanish-language returns or returns for U.S. possessions. The text of those regulations also serves as the text of these proposed regulations.
Employer's Annual Federal Tax Return and Modifications to the Deposit Rules
Document Number: E8-30582
Type: Rule
Date: 2008-12-29
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations relating to the annual filing of Federal employment tax returns and requirements for employment tax deposits. These temporary regulations relate to sections 6011 and 6302 of the Internal Revenue Code (Code) concerning reporting and paying income taxes withheld from wages and reporting and paying taxes under the Federal Insurance Contributions Act (FICA) (collectively, ``employment taxes''). These temporary regulations generally allow certain employers to file a Form 944, ``Employer's ANNUAL Federal Tax Return,'' rather than Form 941, ``Employer's QUARTERLY Federal Tax Return.'' In addition to rules related to Form 944, the temporary regulations provide an additional method for employers who file Form 941 to determine whether the amount of accumulated employment taxes is considered de minimis. The portions of this document that are final regulations provide necessary cross-references to the temporary regulations. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register.
Creditor Continuity of Interest; Correction
Document Number: E8-30717
Type: Rule
Date: 2008-12-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to final regulations (TD 9434) that were published in the Federal Register on Friday, December 12, 2008 (73 FR 75566) providing guidance regarding when and to what extent creditors of a corporation will be treated as proprietors of the corporation in determining whether continuity of interest (''COI'') is preserved in a potential reorganization. These final regulations are necessary to provide clarity to parties engaging in reorganizations of insolvent corporations, both inside and outside of bankruptcy. These final regulations affect corporations, their creditors, and their shareholders.
Creditor Continuity of Interest; Correction
Document Number: E8-30716
Type: Rule
Date: 2008-12-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to final regulations (TD 9434) that were published in the Federal Register on Friday, December 12, 2008 (73 FR75566) providing guidance regarding when and to what extent creditors of a corporation will be treated as proprietors of the corporation in determining whether continuity of interest (``COI'') is preserved in a potential reorganization. These final regulations are necessary to provide clarity to parties engaging in reorganizations of insolvent corporations, both inside and outside of bankruptcy. These final regulations affect corporations, their creditors, and their shareholders.
Proposed Collection; Comment Request for Regulation Project
Document Number: E8-30307
Type: Notice
Date: 2008-12-22
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, REG-209709-94 (TD 8865), Amortization of Intangible Property (Sec. 1.197-2).
Proposed Collection; Comment Request for Revenue Procedure 97-15
Document Number: E8-30305
Type: Notice
Date: 2008-12-22
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 97-15, section 103-Remedial Payment Closing Agreement Program.
Section 6707 and the Failure To Furnish Information Regarding Reportable Transactions
Document Number: E8-30303
Type: Proposed Rule
Date: 2008-12-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations under section 6707 of the Internal Revenue Code (Code), which provide the rules relating to the assessment of penalties against material advisors who fail to timely file a true and complete return required under section 6111(a). The regulations implement the amendments to section 6707 by the American Jobs Creation Act and promote material advisors' compliance with the regulations under section 6111. These regulations affect material advisors responsible for disclosing reportable transactions under section 6111.
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