Internal Revenue Service October 2009 – Federal Register Recent Federal Regulation Documents

Section 108 Reduction of Tax Attributes for S Corporations
Document Number: E9-26152
Type: Rule
Date: 2009-10-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded from gross income
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-26014
Type: Notice
Date: 2009-10-29
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, CO-46-94 (TD 8594), Losses on Small Business Stock (Sec. 1.244(e)-1.
Proposed Collection; Comment Request for Form 2063
Document Number: E9-26013
Type: Notice
Date: 2009-10-29
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 2063, U.S. Departing Alien Income Tax Statement.
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-26012
Type: Notice
Date: 2009-10-29
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, IA-54-90 (TD 8459), Settlement Funds (Sec. Sec. 1.468B-1, 1.468B-2, 1.468B-3, and 1.468B-5).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-26010
Type: Notice
Date: 2009-10-29
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, TD 8712, Definition of Private Activity Bonds (Sec. Sec. 1.141-1, 1.141-12, 1.142-2, and 1.148-6).
Proposed Collection; Comment Request for Form 11-C
Document Number: E9-26009
Type: Notice
Date: 2009-10-29
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 11-C, Occupational Tax and Register Return for Wagering.
Election of Reduced Research Credit Under Section 280C(c)(3); Hearing Cancellation
Document Number: E9-25743
Type: Proposed Rule
Date: 2009-10-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document cancels a public hearing on proposed rulemaking that amends the regulations concerning taxpayers who make the election to claim the reduced research credit. The proposed regulations simplify how taxpayers make the election and affect taxpayers that claim the research credit.
Proposed Collection; Comment Request for Revenue Procedure 97-46 and Revenue Procedure 97-44
Document Number: E9-25741
Type: Notice
Date: 2009-10-27
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 98-46 and Revenue Procedure 97-44, LIFO Conformity Requirement.
Declaratory Judgments-Gift Tax Determinations; Correction
Document Number: E9-25739
Type: Rule
Date: 2009-10-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9460) that were published in the Federal Register on Wednesday, September 9, 2009 (74 FR 46347) regarding petitions filed with the United States Tax Court for declaratory judgments with respect to the valuation of gifts.
Declaratory Judgments-Gift Tax Determinations; Correction
Document Number: E9-25737
Type: Rule
Date: 2009-10-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9460) that were published in the Federal Register on Wednesday, September 9, 2009 regarding petitions filed with the United States Tax Court for declaratory judgments with respect to the valuation of gifts.
Proposed Collection; Comment Request for Form 706-GS(D)
Document Number: E9-25387
Type: Notice
Date: 2009-10-22
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 Form 706-GS(D), Generation-Skipping Transfer Tax Return for Distributions.
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25386
Type: Notice
Date: 2009-10-22
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-105946-00 (TD 8995), Mid-Contract Change in Taxpayer (Sec. 1.460-6).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25385
Type: Notice
Date: 2009-10-22
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-109481-99 (TD 9076), Special Rules Under Section 417(a)(7) for Written Explanation Provided by Qualified Retirement Plan After Annuity Starting Dates (Sec. 1.417(e)-1).
Proposed Collection; Comment Request for Form 6118
Document Number: E9-25384
Type: Notice
Date: 2009-10-22
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 Form 6118, Claim of Income Tax Return Preparer Penalties.
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25383
Type: Notice
Date: 2009-10-22
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, CO-93-90 (TD 8364), Corporations; Consolidated Returns-Special Rules Relating To Dispositions and Deconsolidations of Subsidiary Stock (Sec. Sec. 1.337(d)-2 and 1.1502- 20).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25382
Type: Notice
Date: 2009-10-22
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-246249-96 (TD 9010), Information Reporting Requirements for Certain Payments Made on Behalf of Another Person, Payments to Joint Payees, and Payments of Gross Proceeds From Sales Involving Investment Advisers (Sec. Sec. 1.6041-1 and 1.6045-1).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25381
Type: Notice
Date: 2009-10-22
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, FI-59-91 (TD 8674), Debt Instructions With Original Issue Discount; Contingent Payment; Anti-Abuse Rule (Sec. Sec. 1.1275-2, 1.1275-3, 1.1275-4, and 1.275-6).
Proposed Collection; Comment Request for Regulation Project
Document Number: E9-25280
Type: Notice
Date: 2009-10-22
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-209373-81 (TD 8797), Election to Amortize Start-Up Expenditures for Active Trade or Business (Sec. 1.195-1).
Guidance Under Section 2053 Regarding Post-Death Events
Document Number: E9-25138
Type: Rule
Date: 2009-10-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to the amount deductible from a decedent's gross estate for claims against the estate under section 2053(a)(3) of the Internal Revenue Code (Code). In addition, the regulations update the provisions relating to the deduction for certain state death taxes to reflect the statutory amendments made in 2001 to sections 2053(d) and 2058. The regulations primarily will affect estates of decedents against which there are claims outstanding at the time of the decedent's death.
Measurement of Assets and Liabilities for Pension Funding Purposes; Benefit Restrictions for Underfunded Pension Plans
Document Number: E9-24284
Type: Rule
Date: 2009-10-15
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations providing guidance regarding the determination of the value of plan assets and benefit liabilities for purposes of the funding requirements that apply to single employer defined benefit plans, regarding the use of certain funding balances maintained for those plans, and regarding benefit restrictions for certain underfunded defined benefit pension plans. These regulations reflect provisions added by the Pension Protection Act of 2006, as amended by the Worker, Retiree, and Employer Recovery Act of 2008. These regulations affect sponsors, administrators, participants, and beneficiaries of single employer defined benefit pension plans.
Disregarded Entities and Excise Taxes; Correction
Document Number: E9-24656
Type: Rule
Date: 2009-10-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains a correction to final and temporary regulations (TD 9462) that were published in the Federal Register on Monday, September 14, 2009, clarifying that a single-owner eligible entity that is disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for tax administration purposes related to those excise taxes.
Disregarded Entities and Excise Taxes; Correction
Document Number: E9-24655
Type: Proposed Rule
Date: 2009-10-14
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-116614-08) that was published in the Federal Register on Monday, September 14, 2009, clarifying that a single-owner eligible entity that is disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for tax administration purposes related to those excise taxes.
Period of Limitations on Assessment for Listed Transactions Not Disclosed Under Section 6011
Document Number: E9-24112
Type: Proposed Rule
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations relating to the exception to the general three-year period of limitations on assessment under section 6501(c)(10) of the Internal Revenue Code (Code) for listed transactions that a taxpayer failed to disclose as required under section 6011. These regulations will affect taxpayers who fail to disclose listed transactions in accordance with section 6011.
Open Meeting of Taxpayer Advocacy Panel Notice Improvement Issue Committee
Document Number: E9-24110
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Notice Improvement 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 Advocacy Panel Earned Income Tax Credit Issue Committee.
Document Number: E9-24108
Type: Notice
Date: 2009-10-07
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 Advocacy Panel Joint Committee
Document Number: E9-24107
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Joint 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 Advocacy Panel Taxpayer Assistance Center Committee
Document Number: E9-24106
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Taxpayer Assistance Center 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 Advocacy Panel Small Business/Self Employed Issue Committee
Document Number: E9-24105
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Small Business/ Self Employed 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 Advocacy Panel Multi-Lingual Initiatives Issue Committee
Document Number: E9-24104
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Multi-Lingual Initiatives 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 Advocacy Panel Volunteer Income Tax Assistance Issue Committee
Document Number: E9-24103
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Volunteer Income Tax 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 Advocacy Panel Tax Forms and Publications Issue Committee
Document Number: E9-24102
Type: Notice
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
An open meeting of the Taxpayer Advocacy Panel Tax Forms and Publications 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 Area 1 Taxpayer Advocacy Panel (Including the States of New York, Connecticut, Massachusetts, Rhode Island, New Hampshire, Vermont and Maine)
Document Number: E9-24101
Type: Notice
Date: 2009-10-07
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: E9-24100
Type: Notice
Date: 2009-10-07
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: E9-24099
Type: Notice
Date: 2009-10-07
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 comments, 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: E9-24098
Type: Notice
Date: 2009-10-07
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 comments, 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: E9-24096
Type: Notice
Date: 2009-10-07
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: E9-24095
Type: Notice
Date: 2009-10-07
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 comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Genetic Information Nondiscrimination Act
Document Number: E9-22512
Type: Proposed Rule
Date: 2009-10-07
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
Elsewhere in this issue of the Federal Register, the IRS is issuing temporary and final regulations governing the provisions of the Genetic Information Nondiscrimination Act (GINA) prohibiting discrimination based on genetic information for group health plans. The IRS is issuing the temporary and final regulations at the same time that the Employee Benefits Security Administration of the U.S. Department of Labor and the Centers for Medicare & Medicaid Services of the U.S. Department of Health and Human Services are issuing substantially similar interim final regulations with respect to GINA for group health plans and issuers of health insurance coverage offered in connection with a group health plan under the Employee Retirement Income Security Act of 1974 and the Public Health Service Act. The temporary regulations provide guidance to employers and group health plans relating to the group health plan genetic nondiscrimination requirements. The text of those temporary regulations also serves as the text of these proposed regulations.
Interim Final Rules Prohibiting Discrimination Based on Genetic Information in Health Insurance Coverage and Group Health Plans
Document Number: E9-22504
Type: Rule
Date: 2009-10-07
Agency: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Employee Benefits Security Administration, Department of Labor, Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains interim final rules implementing sections 101 through 103 of the Genetic Information Nondiscrimination Act of 2008. These provisions prohibit discrimination based on genetic information in health insurance coverage and group health plans.
Open Meeting of the Area 5 Taxpayer Advocacy Panel (Including the States of Iowa, Kansas, Minnesota, Missouri, Nebraska, Oklahoma, and Texas)
Document Number: E9-24097
Type: Notice
Date: 2009-10-06
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 comments, ideas, and suggestions on improving customer service at the Internal Revenue Service.
Advisory Committee to the Internal Revenue Service; Meeting
Document Number: E9-24006
Type: Notice
Date: 2009-10-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The Information Reporting Program Advisory Committee (IRPAC) will hold a public meeting on Wednesday, October 28, 2009.
Employer Comparable Contributions to Health Savings Accounts Under Section 4980G, and Requirement of Return for Filing of the Excise Tax Under Section 4980B, 4980D, 4980E or 4980G; Correction
Document Number: E9-24004
Type: Rule
Date: 2009-10-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations that were published in the Federal Register on Tuesday, September 8, 2009, providing guidance on employer comparable contributions to Health Savings Accounts under the Internal Revenue Code (Code) as amended by the Tax Relief and Health Care Act of 2006. The final regulations also provide guidance relating to the manner and method of reporting and paying excise tax.
Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization; Correction
Document Number: E9-23646
Type: Rule
Date: 2009-10-01
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to temporary regulations (TD 9458) that were published in the Federal Register on Friday, September 4, 2009 (74 FR 45757) modifying the election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. This modification was made necessary in light of the regulations under
Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization; Correction
Document Number: E9-23645
Type: Proposed Rule
Date: 2009-10-01
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-139068-08) that were published in the Federal Register on Friday, September 4, 2009 (74 FR 45789) modifying the election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. This modification was made necessary in light of the regulations under