IRS Regulations Issued in 1996 in the Federal Register

REG-246018-96(HTML, 12K)		12/31/1996
Recomputation of Life Insurance Reserves
This document contains proposed regulations relating to the definition of life insurance reserves. The proposed regulations permit the taxpayer or the IRS to recompute certain reserves if those reserves were initially computed or estimated on other than an actuarial basis. The proposed regulations affect both life insurance companies and property and casualty insurance companies. This document also contains a notice of a public hearing on the proposed regulations.
T.D. 8705(HTML, 8K)		12/31/1996
Requirement of Return & Time for Filing
This document contains final and temporary regulations providing that disqualified persons and organization managers liable for Internal Revenue Code section 4958 excise taxes are required to file Form 4720. The regulations also specify the filing date for returns for the period to which the new excise taxes applied retroactively. These excise taxes are imposed on excess benefit transactions between disqualified persons, as statutorily defined, and sections 501(c)(3) and (4) organizations, except for private foundations.
T.D. 8704(HTML, 38K)		12/31/1996
Definition of Foreign Base Company Income & Foreign Personal Holding Company Income of a Controlled Foreign Corporation
This document contains final regulations relating to the definitions of subpart F income and foreign personal holding company income of a controlled foreign corporation and the allocation of deficits for purposes of computing the deemed-paid foreign tax credit. These regulations are necessary to provide guidance that coordinates with previously published guidance under section 954. These regulations will affect United States shareholders of controlled foreign corporations.
T.D. 8700(HTML, 88K)		12/31/1996
Mark to Market for Dealers in Securities
This document contains final regulations providing guidance to enable taxpayers to comply with the mark-to-market requirements applicable to dealers in securities. The Revenue Reconciliation Act of 1993 amended the applicable tax law. These regulations provide guidance to dealers in securities.
T.D. 8706(HTML, 21K)		12/31/1996
Electronic Filing of Form W-4
This document contains final regulations relating to Form W-4, Employee's Withholding Allowance Certificate. The final regulations authorize employers to establish electronic systems for use by employees in filing their Forms W-4. The regulations provide employers and employees with guidance necessary to comply with the law. The regulations affect employers that establish electronic systems and their employees.
REG-247862-96(HTML, 4K)		12/31/1996
Requirement of Return & Time for Filing
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing regulations that provide that disqualified persons and organization managers liable for section 4958 excise taxes are required to file Form 4720. The regulations also specify the filing date for returns for the period to which the new excise taxes apply retroactively. The text of those temporary regulations also serves as the text of these proposed regulations.
REG-209839-96(HTML, 30K)		12/31/1996
Determination of Earned Premiums
This document contains proposed regulations relating to the requirement that insurance companies other than life insurance companies reduce by 20 percent their deductions for increases in unearned premiums. This requirement was enacted as part of the Tax Reform Act of 1986. These regulations are necessary in order to provide guidance to nonlife insurance companies that are subject to the 20 percent reduction rule. This document also contains a notice of a public hearing on the proposed regulations.
T.D. 8675(HTML, 75K)		12/20/1996
Modifications of Debt Instruments
This document contains final regulations relating to the modification of debt instruments. The regulations govern when a modification is treated as an exchange of the original debt instrument for a modified instrument. The regulations provide needed guidance to issuers and holders of debt instruments.
T.D. 8673(HTML, 41K)		12/20/1996
Enterprise Zone Facility Bonds
This document contains final regulations relating to enterprise zone facility bonds issued by State and local governments. These regulations reflect changes to the law made by the Omnibus Budget Reconciliation Act of 1993. These regulations affect issuers of enterprise zone facility bonds.
FI-59-94(HTML, 6K)		12/20/1996
Modifications of Bad Debts & Dealer Assignments of Notional Principal Contracts
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the allowance of a deduction for a partially worthless debt when the terms of a debt instrument have been modified. The temporary regulations provide relief to certain taxpayers that are required to recognize gain as the result of modifying a debt instrument, when a portion of the gain is in part caused by a reduction of the debt's basis attributable to a bad debt deduction claimed in a prior taxable year.
PS-22-96(HTML, 5K)		12/20/1996
Generation-Skipping Transfer Tax
This document contains proposed regulations relating to the final generation-skipping transfer (GST) tax regulations under chapter 13 of the Internal Revenue Code (Code). This document proposes a change to the final regulations and is necessary to provide guidance to taxpayers so that they may comply with chapter 13 of the Code.
T.D. 8676(HTML, 13K)		12/20/1996
Modifications of Bad Debts & Dealer Assignments of Notional Principal Contracts
This document contains temporary regulations relating to the allowance of a deduction for a partially worthless debt when the terms of a debt instrument have been modified. The temporary regulations provide guidance to certain taxpayers that modify the terms of a debt instrument after deducting an amount for partial worthlessness. This document also contains temporary regulations relating to certain assignments of notional principal contracts by dealers in those contracts. The temporary regulations provide guidance to taxpayers relating to consequences of these assignments. 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 of this issue of the Federal Register.
REG-247678-96(HTML, 7K)		12/20/1996
Gasoline & Diesel Fuel Excise Tax; Special Rules for Alaska; Definition of Aviation Gasoline & Kerosene
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the application of the diesel fuel excise tax to fuel used in Alaska. The text of those temporary regulations also serves as a portion of the text of these proposed regulations. This document also contains other proposed regulations relating to gasoline and diesel fuel excise taxes. The proposed regulations implement certain changes made by the Omnibus Budget Reconciliation Act of 1993 and the Small Business Job Protection Act of 1996 and affect certain enterers, refiners, retailers, terminal operators, throughputters, and users.
T.D. 8674(HTML, 206K)		12/20/1996
Debt Instruments with Original Issue Discount; Contingent Payments; Anti-Abuse Rule
This document contains final regulations relating to the tax treatment of debt instruments that provide for one or more contingent payments. This document also contains final regulations that treat a debt instrument and a related hedge as an integrated transaction. In addition, this document contains amendments to the original issue discount regulations, and finalizes the anti-abuse rule relating to those regulations. The final regulations in this document provide needed guidance to holders and issuers of contingent payment debt instruments.
FI-28-96(HTML, 16K)		12/20/1996
Arbitrage Restrictions on Tax-Exempt Bonds
This document contains proposed regulations on the arbitrage restrictions applicable to tax-exempt bonds issued by state and local governments. Changes to applicable law were made by the Tax Reform Act of 1986. These proposed regulations affect issuers of tax-exempt bonds and would provide guidance for complying with the arbitrage regulations.
IA-26-94(HTML, 12K)		12/20/1996
Qualified Small Business Stock
This document contains proposed regulations relating to the 50-percent exclusion for gain from certain small business stock. The proposed regulations reflect changes to the law made by the Omnibus Budget Reconciliation Act of 1993 (OBRA '93) and provide guidance to the issuers and owners of the stock of certain small businesses. This document also provides a notice of public hearing on these proposed regulations.
IL-4-95(HTML, 39K)		12/20/1996
Allocation of Loss on Disposition of Stock
This document contains proposed Income Tax Regulations relating to the allocation of loss realized on the disposition of stock. These regulations will affect United States and foreign shareholders of stock in domestic and foreign corporations. The regulations are necessary to modify existing guidance with respect to stock losses. This document also contains a notice of public hearing on the regulations.
T.D. 8688(HTML, 15K)		12/20/1996
Certain Elections Under the Omnibus Budget Reconciliation Act of 1993
This document contains final regulations relating to the time and manner of making certain elections under the Omnibus Budget Reconciliation Act of 1993. These regulations provide guidance to persons making the elections.
T.D. 8695(HTML, 7K)		12/20/1996
Disclosure of Returns & Return Information to Procure Property or Services for Tax Administration Purposes
This document contains final regulations relating to the disclosure of returns and return information in connection with the procurement of property and services for tax administration purposes. The regulations authorize the Department of Justice, including offices of United States Attorneys, to make such disclosures. Prior to these amendments, disclosure authority within the Department of Justice rested only with the Tax Division. The amendments also reflect a change to the law made by the Omnibus Budget Reconciliation Act of 1990 regarding the type of services about which disclosures may be made.
T.D. 8694(HTML, 9K)		12/20/1996
Disclosure of Return Information to the U.S. Customs Service
These amendments to the regulations under 26 CFR part 301 implement section 6103(l)(14) of the Internal Revenue Code, which authorizes the disclosure of certain return information to the U.S. Customs Service. The regulations specify the procedure by which return information may be disclosed and describe the conditions and restrictions on the use of the information by the U.S. Customs Service.
T.D. 8693(HTML, 10K)		12/20/1996
Diesel Fuel Excise Tax; Special Rules for Alaska
This document contains temporary regulations relating to the application of the diesel fuel excise tax to fuel used in Alaska. The regulations implement certain changes made by the Small Business Job Protection Act of 1996. They affect certain enterers, refiners, retailers, terminal operators, throughputters, wholesale distributors, and users. The text of these 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 of this issue of the Federal Register.
T.D. 8692(HTML, 18K)		12/20/1996
Reissuance of Mortgage Credit Certificates
This document contains final regulations relating to the reissuance of mortgage credit certificates. Changes to the applicable law were made by the Tax Reform Act of 1984. The regulations provide guidance to issuers and holders of mortgage credit certificates.
T.D. 8691(HTML, 8K)		12/20/1996
Sale of Seized Property
This document contains final regulations relating to the sale of seized property. The final regulations reflect changes concerning the setting of a minimum price for seized property by the Tax Reform Act of 1986. The regulations affect all sales of seized property.
REG-209672-93(HTML, 1K)		12/20/1996
Credit for Employer Social Security Taxes Paid on Employee Tips
This document withdraws the notice of proposed rulemaking relating to the credit for employer FICA taxes paid with respect to certain tips received by employees of food or beverage establishments. The proposed regulations were published in the Federal Register on December 23, 1993. Changes to the law made by the Small Business Job Protection Act of 1996 have made these proposed regulations obsolete.
T.D. 8684(HTML, 37K)		12/20/1996
Treatment of Gain from the Disposition of Interest in Certain Natural Resource Recapture Property By S Corporations & Their Shareholders
This document contains final regulations relating to the tax treatment by S corporations and their shareholders of gain from the disposition by an S corporation (and a corporation that was formerly an S corporation) of certain natural resource recapture property (section 1254 property after enactment of the Tax Reform Act of 1986 and oil, gas, or geothermal property before enactment of the Tax Reform Act of 1986), and also rules relating to the disposition of stock in an S corporation that holds certain natural resource recapture property. Changes to the applicable tax law were made by the Tax Reform Act of 1986, and the Subchapter S Revision Act of 1982.
T.D. 8685(HTML, 31K)		11/22/1996
Deposits of Excise Taxes
This document contains final regulations relating to deposits of excise taxes. These regulations reflect changes to the law made by the Uruguay Round Agreements Act and affect persons required to make deposits of excise taxes. This document also removes obsolete excise tax regulations.
REG-251520-96(HTML, 50K)		11/22/1996
Civil Cause of Action for Certain Unauthorized Collection Actions
This document contains proposed regulations relating to civil causes of action for damages caused by unlawful collection actions of officers and employees of the Internal Revenue Service (IRS). The proposed regulations reflect amendments made by the Taxpayer Bill of Rights 2. The proposed regulations affect all taxpayers who file civil actions for damages caused by unlawful collection actions of officers or employees of the IRS.
T.D. 8683(HTML, 22K)		11/6/1996
Magnetic Media Filing Requirements for Information Returns
This document contains regulations relating to the requirements for filing information returns on magnetic media or in other machine-readable form under section 6011(e) of the Internal Revenue Code (Code). These regulations affect persons filing information returns. These regulations prescribe new magnetic media filing requirements for employers filing wage and tax statements for employees in Puerto Rico, U.S. Virgin Islands, Guam, and American Samoa. In addition, these regulations provide taxpayers with the guidance to comply with the changes made to the Code and to the administrative practices with respect to filing on magnetic media or in other machine-readable form.
T.D. 8662(HTML, 9K)		10/8/1996
Diversification of Common Trust Funds
This document contains final regulations relating to the diversification of common trust funds at the time of a combination or division. The final regulations affect common trust funds and their participants.
T.D. 8669(HTML, 32K)		10/8/1996
Computation Of Combined Taxable Income Under the Profit Split Method When the Possession Product Is a Component Product or an End-Product Form for Purposes of the Possessions Credit Under Section 936
This document contains final regulations relating to the computation of combined taxable income under the profit split method. These regulations amend the current regulations and provide revised rules for taxpayers to compute combined taxable income under the profit split method when the possession product chosen for purposes of section 936(h)(5) of the Internal Revenue Code is a component product or an end-product form. These regulations are necessary to provide guidance to taxpayers electing the profit split method of computing taxable income under section 936(h)(5).
DL-40-95(HTML, 9K)		9/27/1996
Disclosure of Returns & Return Information to Procure Property or Services for Tax Administration Purposes
These proposed regulations relate to the disclosure of returns and return information in connection with the procurement of property and services for tax administration purposes. The amendments would authorize the Department of Justice, including offices of United States Attorneys, to make such disclosures. Current disclosure authority within the Department of Justice rests only with the Tax Division. The amendments also reflect a change to the law made by the Omnibus Budget Reconciliation Act of 1990 regarding the type of services about which disclosures may be made.
T.D. 8667(HTML, 24K)		9/26/1996
Lease Term; Exchanges of Tax-Exempt Use Property
This document contains final regulations relating to the lease term of tax-exempt use property. The final regulations also provide guidance regarding certain like-kind exchanges among related parties involving tax-exempt use property.
IA-03-94(HTML, 8K)		9/24/1996
Federal Tax Deposits by Electronic Funds Transfer
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to the deposit of taxes by electronic funds transfer under section 6302(h) of the Internal Revenue Code. The text of the temporary regulations also serves as the comment document for this notice of proposed rulemaking. This document also provides notice of a public hearing on these proposed regulations.
T.D. 8604(HTML, 9K)		9/24/1996
Liability of Third Parties Paying or Providing for Wages: Suit Period & its Extension & Maximum Amount Recoverable.
This document contains final regulations regarding the liability of lenders, sureties, or other third persons for withholding taxes when those persons have supplied funds, either directly to employees or to or for the account of an employer, for the specific purpose of paying wages of the employees of that employer. The final regulations affect third parties paying or providing for wages.
IA-30-95(HTML, 5K)		9/20/1996
Reporting of Nonpayroll Withheld Tax Liabilities
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the reporting of nonpayroll withheld income taxes under section 6011 of the Internal Revenue Code. The text of the temporary regulations also serves as the text for this notice of proposed rulemaking.
REG-208215-91(HTML, 41K)		9/18/1996
Accounting for Long-Term Contracts
This document contains proposed regulations describing how income from a long-term contract must be accounted for under section 460 of the Internal Revenue Code, which was enacted by the Tax Reform Act of 1986. A taxpayer manufacturing or constructing property under a long-term contract will be affected by these proposed regulations. This document also provides notice of a public hearing on the proposed regulations.
IL-0054-95(HTML, 25K)		9/18/1996
Proposed Amendments to the regulations on the Determination of Interest Expense Deduction of Foreign Corporations & Branch Profits Tax
This document contains proposed Income Tax Regulations relating to the determination of the interest expense deduction of foreign corporations under section 882 and the branch profits tax under section 884 of the Internal Revenue Code of 1986. These proposed regulations are necessary to provide guidance that coordinates with guidance provided in final regulations under sections 882 and 884 published elsewhere in this issue of the Federal Register. These regulations will affect foreign corporations engaged in a U.S. trade or business. This document also provides notice of a public hearing on these proposed regulations.
T.D. 8644(HTML, 228K)		9/18/1996
Generation-Skipping Transfer Tax
This document contains final generation-skipping transfer (GST) tax regulations under chapter 13 of the Internal Revenue Code (Code), as added by section 1431 of the Tax Reform Act of 1986. Changes to the applicable law were made by the Tax Reform Act of 1986, the Technical and Miscellaneous Revenue Act of 1988, and the Revenue Reconciliation Act of 1989. The regulations are necessary to provide guidance to taxpayers so that they may comply with chapter 13 of the Code.
IL-0003-95(HTML, 82K)		9/18/1996
Source of Income From Sales of Inventory & Natural Resources Produced in One Jurisdiction & Sold in Another Jurisdiction
This document contains proposed regulations governing the source of income from sales of natural resources or other inventory produced in the United States and sold in a foreign country or produced in a foreign country and sold in the United States. This document affects persons who produce natural resources or other inventory in the United States and sell in a foreign country, or produce natural resources or other inventory in a foreign country and sell in the United States. This document also provides notice of a public hearing on these proposed regulations.
IA-29-96(HTML, 7K)		9/18/1996
Extensions of Time to Make Elections
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to extensions of time for making certain elections under the Internal Revenue Code (Code). The regulations provide the standards that the Commissioner will use to grant taxpayers extensions of time for making these elections. 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 these proposed regulations.
T.D. 8671(HTML, 32K)		9/18/1996
Taxpayer Identifying Numbers (TINs)
This document contains final regulations relating to requirements for furnishing a taxpayer identifying number on returns, statements, or other documents. These regulations set forth procedures for requesting a taxpayer identifying number for certain alien individuals for whom a social security number is not available. These numbers are called "IRS individual taxpayer identification numbers." These regulations also require foreign persons to furnish a taxpayer identifying number on their tax returns.
T.D. 8681(HTML, 7K)		9/18/1996
Time for Performance of Acts Where Last Day Falls on Saturday, Sunday, or Legal Holiday
This document contains final regulations relating to the time for performance of acts by taxpayers and by the Commissioner, a district director, or the director of a regional service center, when the last day for performance falls on a Saturday, Sunday, or legal holiday. In particular, these regulations replace the list of legal holidays with a citation to the District of Columbia law that is the source of the list.
T.D. 8680(HTML, 37K)		9/18/1996
Extensions of Time to Make Elections
This document contains temporary regulations concerning extensions of time for making certain elections under the Internal Revenue Code (Code). The regulations provide the standards that the Commissioner will use to grant taxpayers extensions of time for making these elections. 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 of this issue of the Federal Register.
T.D. 8670(HTML, 14K)		9/18/1996
Revision of Section 482 Cost Sharing Regulations
This document contains final regulations relating to qualified cost sharing arrangements under section 482 of the Internal Revenue Code. These regulations reflect technical changes to the requirements for qualification as a controlled participant under the final cost sharing regulations published in the Federal Register on December 20, 1995.
T.D. 8659(HTML, 112K)		9/18/1996
Gasoline & Diesel Fuel Excise Tax; Registration Requirements
This document contains final regulations relating to the taxes on gasoline and diesel fuel. This document also removes obsolete excise tax regulations. The regulations reflect and implement certain changes made by the Omnibus Budget Reconciliation Act of 1990 and the Omnibus Budget Reconciliation Act of 1993 (the 1993 Act). The regulations affect certain blenders, enterers, industrial users, refiners, terminal operators, and throughputters. The regulations also affect certain persons that sell, buy, or use diesel fuel for a nontaxable use.
T.D. 8664(HTML, 18K)		9/18/1996
Information Reporting & Backup Withholding
This document contains final regulations that provide rules regarding the reporting on Form 1042-S of certain bank deposit interest paid with respect to a United States bank account to an individual who is a nonresident alien of the United States and a resident of Canada. The IRS has determined that information concerning those deposits would be of significant use in furthering its compliance efforts, which include exchange of tax information with Canada.
T.D. 8663(HTML, 8K)		9/18/1996
Transfers to Investment Companies
This document contains final regulations amending regulations under section 351(e) of the Internal Revenue Code relating to transfers to investment companies. The final regulations concern the treatment of certain transfers to a controlled corporation. Generally, the final regulations amend the regulations to provide when certain transfers will not cause a diversification of the transferors' interests.
T.D. 8679(HTML, 44K)		6/28/1996
Regulations Under Section 382 of the Internal Revenue Code of 1986; Application of Section 382 in Short Taxable Years & With Respect to Controlled Groups
This document contains final and temporary regulations relating to limitations on net operating loss carryforwards and certain built-in losses following an ownership change and comply with the statutory direction under section 382(m) of the Internal Revenue Code to prescribe regulations concerning short taxable years and controlled groups. This document also contains amendments relating to the end of separate tracking of the stock ownership of loss corporations that cease to exist following a merger or similar transaction. 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 of this issue of the Federal Register.
T.D. 8678(HTML, 114K)		6/28/1996
Regulations Under Section 1502 of the Internal Revenue Code of 1986; Limitations on Net Operating Loss Carryforwards & Certain Built-In Losses & Credits Following an Ownership Change of a Consolidated Group
This document contains temporary regulations regarding the operation of sections 382 and 383 of the Internal Revenue Code of 1986 (relating to limitations on net operating loss carryforwards and certain built-in losses and credits following an ownership change) with respect to consolidated groups. The regulations include rules for determining whether a loss group or a loss subgroup has an ownership change, for computing a consolidated section 382 limitation or subgroup section 382 limitation, and for applying sections 382 and 383 to corporations that join or leave a group. The rules are necessary to provide guidance to such groups on the use of certain of their tax attributes. 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 of this issue of the Federal Register.
PS-39-93(HTML, 7K)		6/25/1996
Definition of structure
This document contains proposed regulations relating to deductions available upon demolition of a building. These proposed regulations reflect changes to the law made by the Tax Reform Act of 1984 and affect owners and lessees of real property who demolish buildings. This document also provides notice of a public hearing on these regulations.
GL-007-96(HTML, 8K)		6/20/1996
Sale of Seized Property
This document contains proposed regulations relating to the sale of seized property. The proposed regulations reflect changes concerning the setting of a minimum price for seized property by the Tax Reform Act of 1986. The proposed regulations affect all sales of seized property.
CO-9-96(HTML, 10K)		6/20/1996
Section 1059 Extraordinary Dividends
This document contains proposed regulations relating to certain distributions made by corporations to certain corporate shareholders. The proposed regulations are necessary to clarify that certain distributions in redemption of stock are treated as extraordinary dividends notwithstanding provisions that otherwise might exempt the distributions from extraordinary dividend treatment. Corporations that receive a distribution in redemption of stock may be affected if the redemption is either part of a partial liquidation of the redeeming corporation or is not pro rata as to all shareholders. This document also provides notice of a public hearing on these proposed regulations.
FI-32-95(HTML, 42K)		6/20/1996
Mark to Market for Dealers in Securities; Equity Interests In Related Parties & the Dealer-Customer Relationship
This document contains proposed regulations that make mark-to-market accounting inapplicable to most equity interests in related entities. The regulations also relate to the definition of a dealer in securities for certain federal income tax purposes. To qualify as a dealer in securities, a taxpayer must engage in transactions with customers. The proposed regulations concern the existence of dealer-customer relationships. The Revenue Reconciliation Act of 1993 amended the applicable tax law. These regulations provide guidance for taxpayers that engage in securities transactions. This document also provides notice of a public hearing on these proposed regulations.
IA-292-84(HTML, 121K)		6/3/1996
Section 467 Rental Agreement
This document contains proposed regulations relating to the treatment of rent and interest under certain agreements for the lease of tangible property. The proposed regulations apply to certain rental agreements that provide increasing or decreasing rents, or deferred or prepaid rent. This document also provides notice of a public hearing on these regulations.
T.D. 8666(HTML, 17K)		6/3/1996
Payment by Employer of Expenses for Meals & Entertainment, Club Dues, & Spousal Travel.
This document contains final regulations relating to reimbursement and other expense allowance arrangements for expenses of business meals and entertainment that are disallowed as a deduction under section 274(n), and working condition fringe benefit treatment for expenses for club dues and spousal travel that are disallowed as a deduction under sections 274(a)(3) and 274(m)(3). The final regulations reflect changes to the law made by the Omnibus Budget Reconciliation Act of 1993. The persons affected by the final regulations are persons who provide or receive the use of business meals and entertainment, club membership dues, or spousal travel expenses.
PS-29-95(HTML, 17K)		6/3/1996
Available Unit Rule
This document contains proposed regulations concerning the low-income housing credit. The proposed regulations provide rules for determining the treatment of low-income housing units in a building that are occupied by individuals whose incomes increase above 140 percent of the income limitation applicable under section 42(g)(1). The proposed regulations affect owners of those buildings. This document also provides notice of public hearing on these proposed regulations.
T.D. 8616(HTML, 16K)		5/16/1996
Deposits of Excise Taxes
This document contains temporary regulations relating to deposits of excise taxes. These temporary regulations reflect changes to the law made by the Uruguay Round Agreements Act and affect persons required to make deposits of excise taxes. 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 of this issue of the Federal Register.
T.D. 8611(HTML, 158K)		5/16/1996
Conduit Arrangements Regulations
This document contains final regulations relating to conduit financing arrangements issued under the authority granted by section 7701(l). The final regulations apply to persons engaging in multiple-party financing arrangements. The final regulations are necessary to determine whether such arrangements should be recharacterized under section 7701(l).
T.D. 8610(HTML, 53K)		5/16/1996
Taxable Mortgage Pools
This document contains final regulations relating to taxable mortgage pools. This action is necessary because of changes made to the law by the Tax Reform Act of 1986. The final regulations provide guidance to entities for determining whether they are subject to the taxable mortgage pool rules.
T.D. 8609(HTML, 48K)		5/16/1996
Gasohol; Compressed Natural Gas
This document contains final regulations relating to gasohol blending and the tax on compressed natural gas (CNG). The regulations reflect and implement certain changes made by the Energy Policy Act of 1992 (the Energy Act) and the Omnibus Budget Reconciliation Act of 1993 (the 1993 Act). The regulations relating to gasohol blending affect certain blenders, enterers, refiners, and throughputters. The regulations relating to CNG affect persons that sell or buy CNG for use as a fuel in a motor vehicle or motorboat.
T.D. 8606(HTML, 25K)		5/16/1996
Definition of Qualified Electric Vehicle, & Recapture Rules for Qualified Electric Vehicles, Qualified Clean-fuel Vehicle Property, & Qualified Clean-fuel Vehicle Refueling Property
This document contains final regulations on the definition of a qualified electric vehicle, the recapture of any credit allowable for a qualified electric vehicle, and the recapture of any deduction allowable for qualified clean-fuel vehicle property or qualified clean- fuel vehicle refueling property. These regulations reflect changes to the law made by the Energy Policy Act of 1992 and affect taxpayers who are owners of qualified electric vehicles, clean-fuel vehicles, and clean-fuel vehicle refueling property.
T.D. 8600(HTML, 82K)		5/16/1996
Definition of an S corporation
This document contains final regulations relating to the definition of an S corporation under section 1361 of the Internal Revenue Code of 1986. Changes to the applicable tax law were made by the Subchapter S Revision Act of 1982, the Tax Reform Act of 1984, the Tax Reform Act of 1986, the Technical and Miscellaneous Revenue Act of 1988, and the Omnibus Budget Reconciliation Act of 1989. The final regulations provide guidance on the requirements to be an S corporation.
EE-35-95(HTML, 27K)		5/16/1996
Allocation of Accrued Benefits Between Employer & Employee Contributions
This document contains proposed regulations that provide guidance on calculation of an employee's accrued benefit derived from the employee's contributions to a qualified defined benefit pension plan. These regulations are issued to reflect changes to the applicable law made by the Omnibus Budget Reconciliation Act of 1987 (OBRA '87) and the Omnibus Budget Reconciliation Act of 1989 (OBRA '89). OBRA '87 and OBRA '89 amended the law to change the accumulation of employee contributions and the conversion of those accumulated contributions to employee-derived accrued benefits.
T.D. 8635(HTML, 16K)		5/16/1996
Nonbank Trustee Net Worth Requirements
This document contains regulations that provide guidance to nonbank trustees with respect to the adequacy of net worth requirements that must be satisfied in order to be or remain an approved nonbank trustee. These regulations affect nonbank trustees and custodians of individual retirement accounts, and nonbank custodians of qualified plans and tax-sheltered annuities.
T.D. 8595(HTML, 8K)		5/16/1996
Payment of Internal Revenue Tax by Check or Money Order & Liability of Financial Institutions for Unpaid Taxes
This document contains final regulations regarding payments with respect to internal revenue taxes and internal revenue stamps by check or money order. Changes to the applicable tax law were made by the Tax Reform Act of 1984 (TRA). The amendments, which are intended to conform the regulations to the change in the statute, apply to persons making payments with respect to internal revenue taxes or stamps by check or money order and to financial institutions that issue or guarantee payment of checks or money orders.
T.D. 8618(HTML, 252K)		5/16/1996
Definition of a Controlled Foreign Corporation, Foreign Base Company Income & Foreign Personal Holding Company Income of a Controlled Foreign Corporation
This document contains final Income Tax Regulations governing the definition of a controlled foreign corporation and the definitions of foreign base company income and foreign personal holding company income of a controlled foreign corporation. These regulations are necessary because of changes made to the prior law by the Tax Reform Act of 1986, the Technical and Miscellaneous Revenue Act of 1988, the Revenue Reconciliation Act of 1989, and the Omnibus Budget Reconciliation Act of 1993. Certain conforming changes in the regulations were necessary because of changes made by the Deficit Reduction Act of 1984. The regulations will provide the public with the guidance to comply with those acts and will affect United States shareholders of controlled foreign corporations.
IA-33-95(HTML, 4K)		5/16/1996
Effective Date of Temporary Backup Withholding Regulations
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the effective date of the Temporary Employment Tax Regulations under the Interest and Dividend Tax Compliance Act of 1983, relating to backup withholding, statement mailing requirements, and due diligence. The text of those temporary regulations also serves as the text of these proposed regulations.
T.D. 8597(HTML, 322K)		5/16/1996
Consolidated Groups & Controlled Groups--Intercompany Transactions & Related Rules.
This document contains final regulations amending the intercompany transaction system of the consolidated return regulations. The final regulations also revise the regulations under section 267(f), limiting losses and deductions from transactions between members of a controlled group. Amendments to other related regulations are also included in this document.
T.D. 8631(HTML, 31K)		5/16/1996
Notice of Significant Reduction in the Rate of Future Benefit Accrual
This document contains temporary regulations that provide guidance concerning the requirements of section 204(h) of the Employee Retirement Income Security Act of 1974, as amended (ERISA), relating to defined benefit plans and to individual account plans that are subject to the funding standards of section 302 of ERISA. It requires the plan administrator to give notice of certain plan amendments to participants in the plan and certain other parties. 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 published in the Proposed Rules section of this issue of the Federal Register.
T.D. 8642(HTML, 99K)		5/16/1996
Recognition of Gain or Loss by Contributing Partner on Distribution of Contributed Property or Other Property
This document contains final regulations relating to the recognition of gain or loss on certain distributions of contributed property by a partnership under section 704(c)(1)(B) of the Internal Revenue Code of 1986 (Code). This document also contains final regulations relating to the recognition of gain on certain distributions to a contributing partner under section 737. The final regulations affect partnerships and their partners and are necessary to provide guidance for complying with the applicable tax law.
T.D. 8621(HTML, 9K)		5/16/1996
Authority of the Secretary of Agriculture to Share Employer Identification Numbers Collected from Retail Food Stores & Wholesale Food Concerns
This document contains final regulations relating to the authority of the Secretary of Agriculture to share employer identification numbers collected from retail food stores and wholesale food concerns with other agencies or instrumentalities of the United States. These regulations reflect changes to the law made by section 316(b) of the Social Security Independence and Program Improvements Act of 1994 and affect retail food stores and wholesale food concerns.
T.D. 8632(HTML, 103K)		5/16/1996
Section 482 Cost Sharing Regulations
This document contains final regulations relating to qualified cost sharing arrangements under section 482 of the Internal Revenue Code. These regulations reflect changes to section 482 made by the Tax Reform Act of 1986, and provide guidance to revenue agents and taxpayers implementing the changes.
T.D. 8638(HTML, 60K)		5/16/1996
Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations
These temporary regulations provide the public with guidance necessary to comply with the Tax Reform Act of 1984. These regulations amend the Income Tax Regulations with respect to certain transfers of stock or securities of domestic corporations by United States persons to foreign corporations pursuant to the corporate organization, reorganization, or liquidation provisions of the Internal Revenue Code. This Treasury decision also removes certain of the existing temporary regulations regarding transfers by U.S. persons of stock or securities of both domestic and foreign corporations. This action is necessary to update the existing temporary regulations and to reflect certain of the changes announced by Notice 87-85 (1987-2 C.B. 395) (with respect to transfers of both domestic and foreign stock or securities) and by Notice 94-46 (1994-1 C.B. 356) (with respect to transfers of stock or securities of a domestic corporation). 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 of this issue of the Federal Register. When finalized, the regulations under section 367(a) relating to the transfer of stock or securities will integrate the regulations herein with the 1991 proposed regulations relating to transfers of stock or securities (see Proposed Rule 1.367(a)-3 and 1.367(a)-8, published at 56 FR 41993, August 26, 1991).
T.D. 8637(HTML, 213K)		5/16/1996
Backup Withholding, Statement Mailing Requirements, & Due Diligence
This document provides final rules on backup withholding under sections 3406(a)(1)(A), (C), and (D) of the Internal Revenue Code of 1986 (Code) when a payee fails to provide a taxpayer identification number in the required manner to a person required to make an information return, when a payee is subject to notified payee underreporting, or when a payee fails to certify, under penalties of perjury, that the payee is not subject to backup withholding due to notified payee underreporting.
T.D. 8647(HTML, 9K)		5/16/1996
Withholding of Tax on Dispositions of U.S. Real Property Interests by Foreign Persons.
This document contains final regulations relating to withholding upon certain distributions or dispositions of U.S. real property interests. These regulations reflect changes to the law made by the Omnibus Budget Reconciliation Act of 1993 and affect withholding agents required to withhold tax due on certain dispositions and distributions of U.S. real property interests.
T.D. 8634(HTML, 9K)		5/16/1996
Withholding on Distributions of Indian Gaming Profits to Tribal Members
This document contains final regulations relating to the income tax withholding requirement on distributions of profits from certain gaming activities made to members of Indian tribes under section 3402(r) of the Internal Revenue Code of 1986. Those affected by the regulations are persons, including Indian tribes, making payments to members of Indian tribes from net revenues of certain gaming activities conducted or licensed by the tribes. Also affected are members of Indian tribes who receive the payments.
T.D. 8641(HTML, 120K)		5/16/1996
Treatment of Acquisition of Certain Financial Institutions; Certain Tax Consequences of Federal Financial Assistance to Financial Institutions
This document contains final regulations relating to Federal financial assistance, as defined in section 597(c) of the Internal Revenue Code, that is received by a financially troubled bank or thrift institution, and to acquisitions of financially troubled bank or thrift institutions in which Federal financial assistance is provided. This document also contains final regulations under section 7507. These regulations provide guidance concerning the proper tax treatment of various transactions involving the receipt of Federal financial assistance.
T.D. 8630(HTML, 69K)		5/16/1996
Actuarial Tables Exceptions
This document contains final income, estate, and gift tax regulations relating to exceptions to the use of the valuation tables in the regulations for valuing annuities, interests for life or a term of years, and remainder or reversionary interests, the valuation of which was the subject of final regulations published on June 10, 1994. These regulations are necessary in order to provide guidance consistent with court decisions concluding that the valuation tables are not to be used in certain situations.
T.D. 8657(HTML, 52K)		5/16/1996
Regulations on Effectively Connected Income & the Branch Profits Tax
This document contains final Income Tax Regulations relating to the determination of effectively connected income under section 864 and final and temporary Income Tax Regulations relating to the branch profits tax and branch-level interest tax under section 884 of the Internal Revenue Code of 1986 (Code). Section 884 was added to the Code by section 1241 of the Tax Reform Act of 1986. This document also contains conforming changes to sections 861, 871 and 897.
T.D. 8658(HTML, 85K)		5/16/1996
Determination of Interest Expense Deduction of Foreign Corporations
This document contains Income Tax Regulations relating to the determination of the interest expense deduction of foreign corporations and applies to foreign corporations engaged in a trade or business within the United States. This action is necessary because of changes to the applicable tax law made by the Tax Reform Act of 1986, and because of changes in international financial markets.
T.D. 8648(HTML, 41K)		5/16/1996
Controlling Corporation's Basis Adjustment in its Controlled Corporation's Stock Following a Triangular Reorganization.
This document contains final regulations under sections 358, 1032, and 1502 of the Internal Revenue Code of 1986. The final regulations provide rules for adjusting the basis of a controlling corporation in the stock of a controlled corporation as the result of certain triangular reorganizations involving the stock of the controlling corporation. They also generally provide that the use of the controlling corporation's stock provided by the controlling corporation pursuant to the plan of reorganization is treated as a disposition of those shares by the controlling corporation.
T.D. 8656(HTML, 67K)		5/16/1996
Section 6662--Imposition of the Accuracy-Related Penalty
These regulations provide guidance on the imposition of the accuracy related penalty under Internal Revenue Code section 6662(e) for net section 482 transfer price adjustments. This action implements changes to the applicable tax laws made by the Omnibus Budget Reconciliation Act of 1993.
T.D. 8650(HTML, 104K)		5/16/1996
Disallowance of Deductions for Employee Remuneration in Excess of $1,000,000
This document contains final regulations relating to the disallowance of deductions for employee remuneration in excess of $1,000,000. The regulations provide guidance to taxpayers that are subject to section 162(m), which was added to the Code by the Omnibus Budget Reconciliation Act of 1993.
T.D. 8653(HTML, 34K)		5/16/1996
Hedging Transactions by Members of a Consolidated Group
This document contains final regulations relating to the character and timing of gain or loss from certain hedging transactions entered into by members of a consolidated group. These regulations apply when one member of the group hedges its own risk, hedges the risk of another member, or enters into a risk-shifting transaction with another member. The regulations are needed to provide appropriate rules for these transactions. The regulations provide guidance for corporations that are members of consolidated groups.
T.D. 8636(HTML, 22K)		5/16/1996
Time for Furnishing Wage Statements on Termination of Employer's Operations
This document contains final regulations concerning the time for furnishing wage statements to employees and for filing wage statements with the Social Security Administration upon the termination of an employer's operations. These regulations will affect employers and their employees in the year the employer ceases to pay wages. These regulations are intended to improve the wage reconciliation process between the Social Security Administration and the IRS.
EE-20-95(HTML, 23K)		5/9/1996
Effect of the Family & Medical Leave Act on the Operation of Cafeteria Plans
This document contains proposed regulations relating to cafeteria plans that reflect changes made by the Family and Medical Leave Act of 1993. The proposed regulations provide the public with guidance needed to comply with the Act and affect employees who participate in cafeteria plans.
PS-43-95(HTML, 63K)		5/9/1996
Simplification of Entity Classification Rules
This document contains proposed regulations that would replace the existing regulations for classifying certain business organizations with an elective regime. These proposed regulations simplify the existing classification rules.
PS-5-96(HTML, 22K)		5/9/1996
Termination of a Partnership under Section 708(b)(1)(B)
This document contains proposed regulations relating to the termination of a partnership upon the sale or exchange of 50 percent or more of the total interest in partnership capital and profits. The proposed regulations affect all partners and partnerships that terminate under section 708(b)(1)(B).
PS-34-92(HTML, 21K)		5/9/1996
Selection of Tax Matters Partner for Limited Liability Companies
This document contains proposed regulations relating to the designation or selection of a tax matters partner for limited liability companies classified as partnerships. This document also amends current proposed regulations to consolidate certain guidance necessary to determine the tax matters partner for partnerships.
T.D. 8660(HTML, 21K)		5/7/1996
Consolidated Groups--Intercompany Transactions & Related Rules
This document contains final regulations disallowing losses and excluding gain for certain dispositions and other transactions involving stock of the common parent of a consolidated group.
T.D. 8655(HTML, 6K)		5/7/1996
Removal of Final & Temporary Regulations
This document removes final and temporary regulations as part of the President's Regulatory Reinvention Initiative.
T.D. 8654(HTML, 63K)		5/7/1996
Information Reporting for Discharges of Indebtedness
This document contains final regulations relating to the information reporting requirements of applicable financial entities for discharges of indebtedness. The final regulations reflect changes to the Internal Revenue Code of 1986 (Code) made by section 13252 of the Omnibus Budget Reconciliation Act of 1993 (the Act). The final regulations affect certain financial institutions and federal executive agencies.
T.D. 8668(HTML, 18K)		5/7/1996
Environmental Settlement Funds-Classification
This document contains final regulations relating to the classification of certain organizations as trusts for federal tax purposes. The final regulations provide guidance to taxpayers on the proper classification of trusts formed to collect and disburse amounts for environmental remediation of an existing waste site to discharge taxpayers' liability or potential liability under applicable environmental laws.
GL-001-96(HTML, 5K)		5/7/1996
Authority to Modify or Rescind Taxpayer Assistance Orders
This document contains proposed regulations regarding taxpayer assistance orders. The proposed regulations provide that the authority to modify or rescind taxpayer assistance orders is limited to the Commissioner, the Deputy Commissioner, or the Ombudsman. The proposed regulations affect all taxpayers with respect to whom a taxpayer assistance order is issued.
T.D. 8651(HTML, 11K)		5/7/1996
Automatic Extension of Time for Filing Individual Income Tax Returns
This document contains temporary regulations that reflect new simpler procedures for an individual to obtain an automatic extension of time to file an individual income tax return. The text of the temporary regulations also serves as the text of the cross reference notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
EE-142-87(HTML, 161K)		5/7/1996
FICA Taxation of Amounts Under Employee Benefit Plans
This document contains proposed regulations under section 3121(v)(2) of the Internal Revenue Code of 1986, relating to when amounts deferred under or paid from certain nonqualified deferred compensation plans are taken into account as "wages" for purposes of the employment taxes imposed by the Federal Insurance Contributions Act (FICA). The regulations provide guidance to taxpayers who must comply with section 3121(v)(2), which was added to the Code by section 324 of the Social Security Amendments of 1983.
T.D. 8665(HTML, 7K)		5/7/1996
Treatment of Underwriters in Section 351 & Section 721 Transactions
This document contains final regulations concerning transfers of cash to a corporation or a partnership. The final regulations will affect taxpayers in transactions under section 351 or section 721 when there is an offering of stock or partnership interests through an underwriter.
PS-6-95(HTML, 20K)		5/7/1996
Gasoline & Diesel Fuel Excise Tax; Dye Injection Systems & Markers; Measurement
This document contains proposed regulations relating to the gasoline and diesel fuel excise tax. The proposed regulations reflect and implement certain changes made by the Revenue Reconciliation Act of 1990 and the Omnibus Budget Reconciliation Act of 1993 (the 1993 Act). They affect certain enterers, refiners, terminal operators, and throughputters. This document also provides a notice of public hearing on these proposed regulations.
EE-55-95(HTML, 7K)		5/7/1996
FUTA Taxation of Amounts Under Employee Benefit Plans
This document contains proposed regulations under section 3306(r)(2) of the Internal Revenue Code, relating to when amounts deferred under or paid from certain nonqualified deferred compensation plans are taken into account as "wages" for purposes of the employment taxes imposed by the Federal Unemployment Tax Act (FUTA). The regulations provide guidance to taxpayers who must comply with section 3306(r)(2), which was added to the Code by section 324 of the Social Security Amendments of 1983.
IL-062-90(HTML, 391K)		4/17/1996
General Revision of Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons & Related Collection, Refunds, & Credits; Revision of Information Reporting & Backup Withholding Regulations; & Removal of Regulations Under Part 35a & of Certain Regulations Under Income Tax Treaties
This document contains proposed regulations relating to the withholding of income tax under sections 1441 and 1442 on certain U.S. source income paid to foreign persons, the related tax deposit and reporting requirements under section 1461, and the related collection, refunds, and credits of withheld tax under sections 1461 through 1463 and section 6402. Additionally, this document contains proposed regulations relating to the statutory exemption under sections 871(h) and 881(c) for portfolio interest.
EE-53-95(HTML, 9K)		4/4/1996
Requirements for Tax Exempt Section 501(c)(5) Organizations
This document contains proposed regulations clarifying certain requirements of section 501(c)(5). The requirements are being clarified to provide needed guidance to organizations as to the requirements an organization must meet in order to be exempt from tax as an organization described in section 501(c)(5).
EE-24-93(HTML, 7K)		4/4/1996
Notice, Consent, & Election Requirements Under Sections 411(a)(11) & 417
In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance concerning the notice and consent requirements under section 411(a)(11) and the notice and election requirements of section 417. The text of those temporary regulations also serves as the text of these proposed regulations.
EE-106-82(HTML, 38K)		4/4/1996
Loans to plan participants
This document contains proposed Income Tax Regulations under section 72(p) of the Internal Revenue Code relating to loans made from a qualified employer plan to plan participants or beneficiaries. Section 72(p) was added by section 236 of the Tax Equity and Fiscal Responsibility Act of 1982, and amended by the Technical Corrections Act of 1982, the Deficit Reduction Act of 1984, the Tax Reform Act of 1986 and the Technical and Miscellaneous Revenue Act of 1988. These regulations provide guidance to the public with respect to this provision, and affect any plan participant or beneficiary who receives a loan from a qualified employer plan.
T.D. 8661(HTML, 15K)		4/4/1996
Federal Tax Deposits by Electronic Funds Transfer
This document contains temporary regulations relating to the deposit of Federal taxes by electronic funds transfer (EFT) under section 6302 of the Internal Revenue Code. The document also includes temporary regulations providing authority for the voluntary payment of certain Federal taxes by EFT. The regulations would provide the public with additional guidance needed to make deposits by EFT and would affect certain taxpayers not previously required to make deposits by EFT. The text of these temporary regulations also serves as the text of a cross-reference notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.
T.D. 8652(HTML, 16K)		4/4/1996
Cash Reporting by Court Clerks
This document contains final regulations concerning the information reporting requirements of Federal and State court clerks upon receipt of more than $10,000 in cash as bail for any individual charged with a specified criminal offense. The final regulations reflect changes to the law made by the Violent Crime Control and Law Enforcement Act of 1994 (Public Law 103- 322), and affect court clerks who receive more than $10,000 in cash as bail.
T.D. 8649(HTML, 16K)		4/4/1996
Regulations Under Section 1258 of the Internal Revenue Code of 1986; Netting Rule For Certain Conversion Transactions
This document contains final regulations relating to conversion transactions. These regulations provide that certain gains and losses from positions of the same conversion transaction may be netted for purposes of determining the amount of gain that is recharacterized as ordinary income. These regulations reflect changes to the law made by the Revenue Reconciliation Act of 1993 and affect persons who enter into conversion transactions.
T.D. 8645(HTML, 43K)		4/4/1996
Rules for Certain Rental Real Estate Activities
This document contains final regulations providing rules for rental real estate activities of taxpayers engaged in certain real property trades or businesses. The regulations reflect changes to the law made by the Omnibus Budget Reconciliation Act of 1993, and affect taxpayers subject to the limitations on passive activity losses and passive activity credits.
T.D. 8643(HTML, 36K)		4/4/1996
Distributions of Stock & Stock Rights
This document contains final regulations amending regulations under section 305(c) of the Internal Revenue Code relating to constructive distributions on preferred stock. The final regulations concern the treatment of stock redeemable at a premium by the issuer. The regulations generally treat a call premium as giving rise to a constructive distribution only if redemption pursuant to the call provision is more likely than not to occur. The final regulations also reflect 1990 amendments to section 305(c).
T.D. 8640(HTML, 24K)		4/4/1996
Exempt Organizations Not Required To File Annual Returns: Integrated Auxiliaries Of Churches
This document contains final regulations that exempt certain integrated auxiliaries of churches from filing information returns. These regulations incorporate the rules of Rev. Proc. 86-23 (1986-1 C.B. 564), into the regulations defining integrated auxiliary for purposes of determining what entities must file information returns. The new definition focuses on the sources of an organization's financial support in addition to the nature of the organization's activities.
T.D. 8639(HTML, 14K)		4/4/1996
Excise Tax On Self-Dealing By Private Foundations.
This document contains final regulations that clarify the definition of self-dealing for private foundations. These regulations modify the application of the self-dealing rules to the provision by a private foundation of directors' and officers' liability insurance to disqualified persons. In general, these regulations provide that indemnification by a private foundation or provision of insurance for purposes of covering the liabilities of the person in his/her capacity as a manager of the private foundation is not self-dealing. Additionally, the amounts expended by the private foundation for insurance or indemnification generally are not included in the compensation of the disqualified person for purposes of determining whether the disqualified person's compensation is reasonable.
T.D. 8629(HTML, 48K)		4/4/1996
Certain Publicly Traded Partnerships Treated as Corporations
This document contains final regulations relating to the classification of certain publicly traded partnerships as corporations. These regulations provide guidance needed by taxpayers to comply with changes to the law made by the Omnibus Budget Reconciliation Act of 1987. The regulations affect the classification of certain partnerships for federal tax purposes.
T.D. 8628(HTML, 32K)		4/4/1996
Political Expenditures by Section 501(c)(3) Organizations
This document contains final regulations regarding excise taxes, accelerated tax assessments, and injunctions imposed for certain political expenditures made by organizations that (without regard to any political expenditure) would be described in section 501(c)(3) and exempt from taxation under section 501(a). These regulations reflect changes to the law that were enacted as part of the Revenue Act of 1987.
T.D. 8627(HTML, 22K)		4/4/1996
Limitation On Use Of Deconsolidation To Avoid Foreign Tax Credit Limitations
This document contains final regulations relating to certain limitations on the amount of the foreign tax credit under section 904(i). The final regulations will affect the sourcing and foreign tax credit separate limitation character of income for purposes of the calculation of the foreign tax credit by certain related domestic corporations. The final regulations are necessary to prevent avoidance of the foreign tax credit limitations.
T.D. 8626(HTML, 16K)		4/4/1996
Continuity of Interest in Transfer of Target Assets After Qualified Stock Purchase of Target
This document prescribes final regulations under section 338 of the Internal Revenue Code regarding the transfer of target assets to the purchasing corporation or another member of the same affiliated group as the purchasing corporation after a qualified stock purchase (QSP) of target stock, if a section 338 election is not made. These regulations provide guidance to parties to such transfers.
T.D. 8615(HTML, 14K)		4/4/1996
Special Rules for Determining Sources of Scholarships & Fellowship Grants
This document contains a final Income Tax Regulation that provides guidance for determining the source of scholarships, fellowship grants, grants, prizes and awards. The final regulation will affect both individuals and withholding agents. It will provide guidance concerning whether scholarships, fellowships, other grants, prizes and awards are U.S. source income subject to tax and withholding.
T.D. 8625(HTML, 7K)		4/4/1996
Seals of Office
This document contains final regulations relating to the authority contained within section 7514 of the Internal Revenue Code to prescribe or modify seals of office. These regulations provide an additional or alternative uniform seal for use by internal revenue offices throughout the country. In addition this regulation publishes what will be the newly reorganized regional and district offices, computing centers, submission processing centers, and customer service centers of the IRS.
T.D. 8646(HTML, 62K)		4/4/1996
Allocation & Apportionment of Research & Experimental Expenditures
This document provides guidance concerning the allocation and apportionment of research and experimental expenditures for purposes of determining taxable income from sources within and without the United States. This document affects taxpayers that have income from United States and foreign sources and that have made expenditures for research and experimentation that the taxpayer deducts under section 174 of the Internal Revenue Code of 1986.

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