| T.D. 8852(PDF, 71K) |
HTML Version(79K) |
12/30/1999 |
| Passthrough of Items of an S Corporation to its Shareholders |
| This document contains final regulations relating to the passthrough of items of an S corporation to its shareholders, the adjustments to the basis of stock of the shareholders, and the treatment of distributions by an S corporation. These regulations provide S corporations and their shareholders with guidance needed to comply with the applicable law. |
| REG-101492-98(PDF, 29K) |
HTML Version(27K) |
12/30/1999 |
| Relief for Service in Combat Zone & for Presidentially Declared Disaster |
| The Internal Revenue Service has published regulations allowing the Commissioner to postpone certain tax-related deadlines for taxpayers affected by a Presidentially declared disaster. Examples of deadlines that may be postpone include the time for filing most income tax, estate tax, gift tax, excise tax, and employment tax returns, the time for paying these taxes, and the time for filing claims for refund. |
| T.D. 8856(PDF, 61K) |
HTML Version(31K) |
12/30/1999 |
| 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 Parts 1 & 35a & of Certain Regulations Under Income Tax Treaties |
| This REG-extends the effective date of the final Regulations under section 1441-1463 and 6041-16050N of the Code, and related provisions until January 1, 2001. |
| T.D. 8850(PDF, 65K) |
HTML Version(66K) |
12/29/1999 |
| Information Reporting With Respect to Certain Foreign Partnerships & Certain Foreign Corporations |
| The final regulations require certain U.S. partners of controlled foreign partnerships (CFPs) to report information about the CFPs. The final regulations describe the kind of information that must be provided and provide exceptions to the reporting obligation. The information must be reported on new Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships. |
| REG-106012-98(PDF, 44K) |
HTML Version(31K) |
12/22/1999 |
| Definition of Contribution in Aid of Construction Under Section 118(c) |
| Corporations do not have to include into gross income amounts received as a contribution to capital. A contribution to the capital of a corporation may include any amount of money or other property received from any person (whether or not a shareholder) by a regulated public utility that provides water or sewerage disposal services if the amount is a contribution in aid of construction (CIAC). The exclusion from gross income for a CIAC applies to any amount of money or other property received by a regulated public utility after June 12, 1996. |
| T.D. 8847(PDF, 107K) |
HTML Version(123K) |
12/16/1999 |
| Adjustments Following Sales of Partnership Interests |
| Section 743 of the Internal Revenue Code provides rules for adjusting the basis of partnership property following certain transfers of interests in partnerships that have made an election under section 754. These final regulations provide guidance for determining the proper amount of the basis adjustment and for allocating the adjustment among the various items of partnership property under section 755. |
| T.D. 8846(PDF, 29K) |
HTML Version(28K) |
12/7/1999 |
| Deductions for Transfers for Public, Charitable, & Religious Uses; In General Marital Deduction; Valuation of Interest Passing to Surviving Spouse |
| These final regulations provide rules relating to the effect of certain administration expenses on the valuation of property which qualifies for either the estate tax charitable deduction under section 2055 of the Internal Revenue Code or the estate tax marital deduction under section 2056. The regulations distinguish between estate transmission expenses, which reduce the value of property for marital and charitable deduction purposes, and estate management expenses which generally do not reduce the value of the property for these purposes. |
| T.D. 8845(PDF, 64K) |
HTML Version(50K) |
12/7/1999 |
| Adequate Disclosure of Gifts |
| These regulations describe information that must be submitted when an individual reports a gift on a Federal gift tax return, in order to start the three year time period within which the Service must examine the return and determine if additional tax is due. Generally, if an individual provides the required information, the Service will be precluded from asserting that any additional gift tax is due after the three year period from the date of filing the return expires. |
| T.D. 8844(PDF, 34K) |
HTML Version(35K) |
11/30/1999 |
| Treatment of Changes in Elective Entity Classification |
| This document contains final regulations describing how elective changes in classification will be treated for federal tax purposes. The final regulations affect business entities and their members. The final regulations provide guidance to taxpayers who elect to change an entity's classification for federal tax purposes. |
| T.D. 8843(PDF, 15K) |
HTML Version(15K) |
11/12/1999 |
| Partnership Returns Required on Magnetic Media |
| Pursuant to changes made by the Taxpayer Relief Act of 1997, the IRS published regulations to require that partnerships with more than 100 partners file partnership returns on magnetic media. The regulations authorize the IRS to waive the magnetic media requirement in case of hardship. The regulations are generally effective for partnership returns for tax years ending on or after December 31, 2000. However, the regulations are not effective for returns of electing large partnerships and partnerships using foreign addresses on their Series 1065 forms for tax years ending before January 1, 2001. |
| T.D. 8842(PDF, 10K) |
HTML Version(8K) |
11/10/1999 |
| Acquisition of an S Corporation by a Member of a Consolidated Group |
| When a consolidated group acquires an S corporation, the interaction of the consolidated return regulations and the subchapter S rules requires the filing of a separate return for the day of the acquisition. As a result, the day of the acquisition is treated as a separate tax year. This regulation eliminates the requirement of filing a separate return for the day of the acquisition. Instead, the day of the acquisition will be included in the consolidated group's return. |
| T.D. 8841(PDF, 32K) |
HTML Version(30K) |
11/10/1999 |
| Return of Partnership Income |
| The Internal Revenue Code requires every partnership to file a partnership tax return. A foreign partnership, however, does not have to file a return unless it receives income from United States sources or from a U.S. trade or business. Congress has authorized the Internal Revenue Service to provide exceptions and simplified filing procedures for foreign partnerships. These regulations provide guidance to domestic and foreign partnerships in meeting their tax return filing obligations. |
| T.D. 8839(PDF, 17K) |
HTML Version(14K) |
11/10/1999 |
| IRS Adoption Taxpayer Identification Numbers |
| Recent tax law changes require a taxpayer to provide a child's taxpayer identification number (TIN) to claim certain tax benefits for the child. An individual's TIN is generally the individual's social security number (SSN). The Internal Revenue Service has published regulations to assign Adoption Taxpayer Identification Numbers (ATINs) to a child placed for adoption for whom the prospective adoptive parents cannot obtain an SSN. The parent will apply for an ATIN using a new tax form, Form W-7A. |
| T.D. 8840(PDF, 16K) |
HTML Version(9K) |
11/10/1999 |
| Reopenings of Treasury Securities; Original Issue Discount |
| The temporary regulations (TD 8840) amend §1.1275-2(d) by eliminating the acute, protracted shortage requirement for a reopening of Treasury securities to be a qualified reopening. |
| REG-116125-99(PDF, 21K) |
HTML Version(19K) |
10/19/1999 |
| Prevention of Abuse of Charitable Remainder Trusts |
| This document contains proposed regulations that modify the application of the rules governing the character of certain distributions from a charitable remainder trust. These regulations are necessary to prevent taxpayers from using charitable remainder trusts to achieve inappropriate tax avoidance. The regulations affect charitable remainder trusts described in section 664 and certain beneficiaries of those trusts. |
| REG-252487-96(PDF, 9K) |
HTML Version(5K) |
10/12/1999 |
| Inbound Grantor Trusts With Foreign Grantors |
| The IRS is proposing regulations relating to the definition of the term grantor for purposes of part I of subchapter J, chapter 1 of the Internal Revenue Code. The text of temporary regulations published elsewhere in this issue of the Federal Register, also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations. |
| REG-121063-97(PDF, 27K) |
HTML Version(28K) |
10/7/1999 |
| Averaging of Farm Income |
| These proposed regulations provide rules regarding how an individual engaged in a farming business may elect to "average" farm income over the three prior years. The rules will not be adopted until tax years ending on or after the date of publication of the final version of these regulations in the Federal Register. However, until then, an individual may rely on the proposed regulations to prepare income tax returns for taxable periods ending before the publication of the final regulations. |
| REG-106010-98(PDF, 36K) |
HTML Version(24K) |
9/20/1999 |
| Qualified Lessee Construction Allowances for Short-Term Leases |
| Generally, the receipt of a construction allowance by a lessee from a lessor for property to be constructed and used by the lessee pursuant to a lease is gross income to the lessee in the year of receipt. However, amounts received by a lessee that are expended by the lessee on assets owned by the lessor are not includible in the lessee's gross income because the lessee is acting as the lessor's agent in constructing the improvements. |
| T.D. 8838(PDF, 20K) |
HTML Version(13K) |
9/3/1999 |
| Inflation-Indexed Debt Instruments |
| The final regulations, which will be published in the Federal Register on September 7, 1999, provide rules for the taxation of inflation-indexed debt instruments, including Treasury Inflation-Indexed Securities. The regulations generally require holders and issuers of these debt instruments to account for an increase in principal amount due to inflation as additional interest for the taxable year in which the increase occurs. |
| T.D. 8837(PDF, 8K) |
HTML Version(7K) |
9/3/1999 |
| Revision of the Tax Refund Offset Program |
| These regulations implement the merger of the Tax Refund Offset Program (TROP) into the Treasury Offset Program (TOP). The merger of the two programs is intended to maximize and improve the Treasury Department's government-wide collection of nontax debts, including those subject to offset against the debtor's Federal tax refund. The full merger is effective for refunds payable after January 1, 1999. The full text of the regulations is set forth in the Federal Register dated. |
| REG-105565-99(PDF, 16K) |
HTML Version(14K) |
8/31/1999 |
| Arbitrage Restrictions Applicable to Tax-Exempt Bonds Issued by State & Local Governments |
| The proposed regulations set forth a rule for determining whether a broker's commission or similar fee incurred in connection with a guaranteed investment contract or investments purchased for a yield restricted defeasance escrow can be treated as a qualified administrative cost. |
| T.D. 8830(PDF, 31K) |
HTML Version(21K) |
8/30/1999 |
| Establishment of a Balanced Measurement System |
| These regulations establish a balanced set of performance measures for organizational units within the Internal Revenue Service, consisting of Customer Satisfaction, Employee Satisfaction and Business Results (quality and quantity). The regulations also contain rules relating to the evaluation of IRS employees, including a prohibition of the use of records of tax enforcement results to evaluate or to impose or suggest goals for such employees. The rules are effective September 7, 1999. The full text of regulations is published in the Federal Register for August 6, 1999. |
| REG-113526-98(PDF, 18K) |
HTML Version(13K) |
8/25/1999 |
| Arbitrage & Related Restrictions Applicable to Tax-exempt Bonds Issued by State & Local Governments, Investment-Type Property |
| State and local governments that issue tax-exempt bonds are subject to arbitrage and related restrictions. These restrictions apply to investment-type property. The proposed regulations which were published in the Federal Register, clarify which prepayments are investment-type property. |
| T.D. 8836(PDF, 20K) |
HTML Version(15K) |
8/25/1999 |
| Capital Gains, Installment Sales, Unrecaptured Section 1250 Gain |
| Final Regulations Regarding Taxation Of Capital Gains On Installment Sales Of Depreciable Real Property. The IRS is issuing final regulations to provide guidance on the taxation of capital gains on installment sales of depreciable real property. Section 453 provides that, unless taxpayers elect out, gain from an installment sale is recognized as payments on the installment obligation are received. Section 1(h) generally divides net capital gain into three rate groups but does not address how to treat amounts taken into account after May 6, 1997. |
| T.D. 8835(PDF, 10K) |
HTML Version(6K) |
8/11/1999 |
| Furnishing Identifying Number of Income Tax Return Preparer |
| The IRS is issuing regulations that allow income tax return preparers to use a number other than their social security number when identifying themselves on returns they prepare. The regulations provide that the Internal Revenue Service may prescribe this alternative number in forms, instructions, or other appropriate guidance. These regulations apply to tax returns or claims for refund filed after December 31, 1999. The full text of the regulations is set forth in the Federal Register dated August 12, 1999. |
| REG-105237-99(PDF, 8K) |
HTML Version(4K) |
8/11/1999 |
| Furnishing Identifying Number of Income Tax Return Preparer |
| The IRS is issuing proposed regulations that would allow income tax return preparers to use a number other than their social security number when identifying themselves on returns they prepare. The proposed regulations provide that the Internal Revenue Service may prescribe this alternative number in forms, instructions, or other appropriate guidance. These regulations apply to tax returns or claims for refund filed after December 31, 1999. The full text of the regulations is set forth in the Federal Register dated August 12, 1999. Written comments are being accepted through November 10, 1999. |
| T.D. 8833(PDF, 36K) |
HTML Version(35K) |
8/11/1999 |
| Consolidated Returns--Consolidated Overall Foreign Losses & Separate Limitation Losses |
| Corporations that file consolidated tax returns and claim foreign tax credits must generally keep accounts for certain foreign losses, called consolidated overall foreign loss accounts. These accounts affect the amount of foreign tax credits that a consolidated group is permitted to claim. The regulation modifies the rules that apply to these accounts when a corporation leaves a consolidated group. |
| REG-121946-98(PDF, 41K) |
HTML Version(25K) |
8/10/1999 |
| Private Foundation Disclosure Rules |
| Proposed Regulations Relating to the Public Disclosure Requirements of Section 6104(d) of the Internal Revenue Code Applicable to Private Foundations. The proposed regulations relate to the application and returns a private foundation, must make available for public inspection and must supply in response to requests for copies. The proposed regulations also prescribe how a private foundation can make these documents widely available. |
| T.D. 8831(PDF, 92K) |
HTML Version(102K) |
8/10/1999 |
| Inbound Grantor Trusts With Foreign Grantors |
| Foreign families often establish offshore trusts for the benefit of U.S. family members. Under prior law, distributions from such trusts were often treated as nontaxable gifts. Under these final regulations, which implement provisions of the Small Business Job Protection Act of 1996, most distributions from offshore trusts will be taxable to the U.S. family members. |
| T.D. 8834(PDF, 79K) |
HTML Version(81K) |
8/10/1999 |
| Treatment of Distributions to Foreign Persons Under Sections 367(e)(1) & 367(e) |
| This document amends the Income Tax Regulations by removing temporary regulations on the treatment of distributions to foreign persons under section 367(e) of the Internal Revenue Code and adding final regulations under section 367(e). These final regulations are necessary to implement section 367(e)(1) and (2), as added to the Internal Revenue Code by the Tax Reform Act of 1986, which affects U.S. corporations. |
| T.D. 8832(PDF, 21K) |
HTML Version(15K) |
8/5/1999 |
| Exception From Supplemental Annuity Tax on Railroad Employers |
| The Railroad Retirement Tax Act imposes a supplemental annuity tax on railroad employers to fund the Railroad Retirement Board's supplemental annuity benefit. An exception from this tax applies for employees covered by a supplemental pension plan established by a collective bargaining agreement. These regulations, which were published in the Federal Register of August 6, 1999, provide rules for applying this exception. |
| REG-106527-98(PDF, 47K) |
HTML Version(45K) |
8/5/1999 |
| Capital Gains, Partnership, Subchapter S, & Trust Provisions |
| The proposed regulations explain how to calculate the capital gain recognized by a taxpayer who sells all or part of an interest in a partnership, an S corporation, or a trust if the entity owns certain types of property. The types of property that can give rise to higher rate of long-term capital gain when an interest in an entity is sold are collectibles (held by a partnership, s corporation, or trust) and depreciable real estate (held by a partnership). |
| T.D. 8824(PDF, 242K) |
HTML Version(246K) |
8/2/1999 |
| 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 final 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. |
| T.D. 8823(PDF, 157K) |
HTML Version(179K) |
8/2/1999 |
| Consolidated Returns--Limitations on the Use of Certain Losses & Deductions |
| These final regulations provide rules limiting a consolidated group's use of attributes of corporations that arise in separate return limitation years (SRLY). However, in certain circumstances in which these rules would otherwise overlap a limitation provided by section 382, the SRLY limitation will not apply. |
| T.D. 8825(PDF, 40K) |
HTML Version(22K) |
8/2/1999 |
| 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 regulations relating to limitations on net operating loss carryovers and certain built-in losses following an ownership change of a corporation. The regulations implement the statutory authority under section 382(m) of the Internal Revenue Code to prescribe regulations concerning short taxable years and controlled groups of corporations. Additional rules are adopted relating principally to corporations that cease to exist following a merger (or similar transaction) or that have two or more ownership changes. |
| REG-116991-98(PDF, 12K) |
HTML Version(6K) |
7/20/1999 |
| Compromises |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the compromise of tax liabilities. These regulations provide additional guidance regarding the compromise of internal revenue taxes. The temporary regulations reflect changes to the law made by the Internal Revenue Service Restructuring and Reform Act of 1998 and the Taxpayer bill of Rights II. The text of the temporary regulations also serves as the text of these proposed regulations. |
| T.D. 8829(PDF, 57K) |
HTML Version(46K) |
7/20/1999 |
| Compromises |
| The purpose of this regulation is to provide procedures for the compromise of internal revenue tax and to provide expanded compromise authority for the IRS. The regulation will permit compromise of liabilities when there is doubt as to the amount of the liability owed, when there is doubt whether the full amount of the tax can be collected, and when, in light of all the facts and circumstances, collection of the full amount of the tax liability would create economic hardship or be detrimental to voluntary compliance. |
| T.D. 8828(PDF, 16K) |
HTML Version(12K) |
7/13/1999 |
| Electronic Funds Transfers of Federal Deposits |
| For calendar years beginning after 1999, these final regulations describe the taxpayers that must begin to deposit by electronic funds transfer (EFT), the types of federal taxes that must be deposited by EFT, and when deposits by EFT must commence. The full text of the final regulations is set forth in the Federal Register dated July 13, 1999. |
| REG-105327-99(PDF, 10K) |
HTML Version(6K) |
7/13/1999 |
| Qualified Zone Academy Bonds; Obligations of States & Political Subdivisions |
| Under these regulations, guidance will be published in the Internal Revenue Bulletin for ascertaining the credit rate for qualified zone academy bonds. These regulations also provide that proceeds of qualified zone academy bonds may be used to reimburse a qualified expenditure under rules similar to §1.150-2. |
| T.D. 8826(PDF, 10K) |
HTML Version(7K) |
7/13/1999 |
| Qualified Zone Academy Bonds; Obligations of States & Political Subdivisions |
| Under these regulations, guidance will be published in the Internal Revenue Bulletin for ascertaining the credit rate for qualified zone academy bonds. These regulations also provide that proceeds of qualified zone academy bonds may be used to reimburse a qualified expenditure under rules similar to §1.150-2. |
| T.D. 8822(PDF, 8K) |
HTML Version(4K) |
6/16/1999 |
| Federal Employment Tax Deposits-De Minimis Rule |
| These final regulations adopt the rules of temporary regulations that raise the de minimis amount for the making of employment tax deposits from $500 to $1,000 per return period. The regulations are effective for return periods beginning on or after July 1, 1998, for quarterly filers and January 1, 1999, for annual filers. The full text of the regulations is set forth in the Federal Register dated June 17,1999. |
| T.D. 8821(PDF, 23K) |
HTML Version(19K) |
6/2/1999 |
| Group-Term Insurance; Uniform Premiums |
| These regulations revise the uniform premium table used to calculate the cost of group-term life insurance coverage provided to an employee by an employer. These regulations provide guidance to employers who provide group-term life insurance coverage to their employees that is includible in the gross income of the employees. |
| REG-105312-98(PDF, 27K) |
HTML Version(23K) |
5/21/1999 |
| Reporting of Gross Proceeds Payments to Attorneys |
| This document contains proposed regulations relating to the reporting of payments of gross proceeds to attorneys. The regulations reflect changes to the law made by the Taxpayer Relief Act of 1997. The regulations will affect attorneys who receive payments of gross proceeds on behalf of their clients, and certain payors (defendants in lawsuits and their insurance companies and agents) that in the course of their trades or businesses make payments to these attorneys. This document also provides notice of a public hearing on these proposed regulations. |
| T.D. 8820(PDF, 198K) |
HTML Version(224K) |
5/19/1999 |
| Section 467 Rental Agreements; Treatment of Rent & Interest Under Certain Agreements for the Lease of Tangible Property |
| This document contains final regulations relating to the treatment of rent and interest under certain agreements for the lease of tangible property. The regulations apply to certain rental agreements that provide increasing or decreasing rents, or deferred or prepaid rent, and provide guidance for lessees and lessors of tangible property. |
| REG-100905-97(PDF, 13K) |
HTML Version(8K) |
5/19/1999 |
| Real Estate Mortgage Investment Conduits; Reporting Requirements & Other Administrative Matters |
| Information no longer required to be placed on CDO or REMIC certificates These proposed regulations would rescind the requirement that certain information related to the accrual of original issue discount (OID) be set forth on the face of a collateralized debt obligation (CDO) or regular interest in a real estate mortgage investment conduit (REMIC). |
| REG-103694-99(PDF, 10K) |
HTML Version(7K) |
5/19/1999 |
| Section 467 Rental Agreements Involving Payments of $2,000,000 or Less |
| This document contains proposed regulations concerning section 467 rental agreements. The regulations remove the constant rental accrual exception for rental agreements involving payments of $2,000,000 or less. The regulations affect taxpayers that are parties to a section 467 rental agreement entered into on or after July 19, 1999. |
| REG-208156-91(PDF, 140K) |
HTML Version(152K) |
4/30/1999 |
| 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. DATES: Written comments and outlines of oral comments to be presented at the public hearing scheduled for September 14, 1999, at 10 a.m. must be received by August 3, 1999. |
| REG-103851-99(PDF, 17K) |
HTML Version(11K) |
4/29/1999 |
| Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, & Remainder or Reversionary Interests |
| These regulations revise certain tables used for the valuation of annuities, interests for life or a term of years, and remainder or reversionary interests under section 7520 of the Internal Revenue Code to reflect data compiled from the 1990 census. |
| REG-106004-98(PDF, 125K) |
HTML Version(123K) |
4/29/1999 |
| Guidance Under Section 355(d); Recognition of Gain on Certain Distributions of Stock or Securities |
| This document contains proposed regulations relating to recognition of gain on certain distributions of stock or securities of a controlled corporation. These proposed regulations affect corporations and their shareholders. Proposed regulations are necessary because of statutory changes made by the Omnibus Budget Reconciliation Act of 1990. This document also provides notice of a public hearing on these proposed regulations. |
| T.D. 8819(PDF, 226K) |
HTML Version(256K) |
4/29/1999 |
| Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, & Remainder or Reversionary Interests |
| These regulations revise certain tables used for the valuation of annuities, interests for life or a term of years, and remainder or reversionary interests under section 7520 of the Internal Revenue Code to reflect data compiled from the 1990 census. |
| REG-100729-98(PDF, 21K) |
HTML Version(19K) |
3/26/1999 |
| Electronic Funds Transfers of Federal Deposits |
| For calendar years beginning after 1999, these proposed regulations describe the taxpayers that must begin to deposit by electronic funds transfer (EFT), the types of federal taxes that must be deposited by EFT, and when deposits by EFT must commence. The full text of the proposed regulations is set forth in the Federal Register dated March 23, 1999. |
| T.D. 8817(PDF, 33K) |
HTML Version(30K) |
2/5/1999 |
| Notice of Certain Transfers to Foreign Partnerships & Foreign Corporations |
| The final regulations provide rules for reporting transfers by U.S. persons of cash to foreign corporations and reporting certain transfers by U.S. persons of property to foreign partnerships. The final regulations describe the kind of information that must be provided and the manner in which it must be reported. In addition, the IRS and Treasury are creating a new form, Form 8865, to be used for reporting transfers to foreign partnerships under the final regulations. |
| REG-121865-98(PDF, 162K) |
HTML Version(105K) |
2/5/1999 |
| Continuation Coverage Requirements Applicable to Group Health Plans |
| These proposed regulations provide guidance on the COBRA continuation coverage requirements for group health plans. When finalized, the regulations will affect many businesses, nonprofit organizations and individuals. The full text of the notice of proposed rulemaking for the proposed regulations can be found in the Federal Register for February 3, 1999. |
| T.D. 8812(PDF, 293K) |
HTML Version(211K) |
2/5/1999 |
| Continuation Coverage Requirements Applicable to Group Health Plans |
| These final regulations provide guidance on the COBRA continuation coverage requirements for group health plans. The regulations affect many businesses, nonprofit organizations, and individuals. The full text of the regulations, along with a preamble explaining the regulations, can be found in the Federal Register for February 3, 1999. |
| T.D. 8816(PDF, 92K) |
HTML Version(104K) |
2/5/1999 |
| Roth IRAs |
| These final regulations provide guidance, in a question and answer format, on Roth IRAs. These final regulations affect individuals establishing Roth IRAs, beneficiaries under Roth IRAs, and trustees, issuers, or custodians of Roth IRAs. |
| INTL-941-86(PDF, 5K) |
HTML Version(2K) |
2/1/1999 |
| Withdrawal of Guidance Under Section 1291 Relating to Mark to Market Elections for RICs |
| This document withdraws a portion of a regulation, proposed in 1992, under the passive foreign investment company ("PFIC") rules relating to a mark to market election for regulated investment companies (RICs) that are shareholders of PFICs. |
| REG-119192-98(PDF, 60K) |
HTML Version(49K) |
2/1/1999 |
| Establishment of a Balanced Measurement System |
| These proposed regulations further implement a requirement that all employees be evaluated on whether they provided fair and equitable treatment to taxpayers and bar use of records of tax enforcement results to evaluate or to impose or suggest goals for any employee of the IRS. These regulations implement sections 1201 and 1204 of the Internal Revenue Restructuring and Reform Act of 1998. These regulations affect internal operations of the IRS and the systems that agency employs to evaluate the performance of organizations within IRS and individuals employed by IRS. |
| T.D. 8813(PDF, 61K) |
HTML Version(59K) |
2/1/1999 |
| Residence of Trusts & Estates--7701 |
| The final regulations provide guidance under the new law, concerning whether a trust is a domestic trust or a foreign trust for federal tax purposes. Under the new law, trusts are domestic trusts if a court within the United States is able to exercise primary supervision over the administration of the trust, and one or more United States persons have the authority to control all substantial decisions of the trust. If a trust fails either test, the trust is a foreign trust. The regulations also provide guidance regarding an election for certain trusts to remain domestic... |
| REG-104924-98(PDF, 35K) |
HTML Version(31K) |
1/28/1999 |
| Mark-to-Market Accounting for Dealers in Commodities & Traders in Securities or Commodities |
| The Taxpayer Relief Act of 1997 allows securities traders and commodities traders and dealers to elect mark-to-market accounting for their businesses, for tax years ending after August 5, 1997. These proposed regulations, which were published in the Federal Register of XXX, 1998, clarify several issues relating to these elections, including the identification of securities and commodities as exempt from mark-to-market accounting, the character of marked securities and commodities, and the time and manner for making the elections. Further, these proposed regulations provide that, until further guidance is published,... |
| T.D. 8814(PDF, 205K) |
HTML Version(209K) |
1/28/1999 |
| Federal Insurance Contributions Act (FICA) Taxation of Amounts Under Employee Benefit Plans |
| These final regulations provide guidance on section 3121(v) of the Internal Revenue Code, which deals with FICA taxes on nonqualified deferred compensation. The regulations are effective January 1, 2000 and affect many businesses, nonprofit organizations, governments, and individuals. The full text of the regulations is in the Federal Register dated January 29, 1999. |
| REG-106388-98(PDF, 73K) |
HTML Version(83K) |
1/28/1999 |
| Education Tax Credits |
| The IRS is issuing proposed regulations that provide guidance to individual taxpayers who may claim the Hope Scholarship Credit or the Lifetime Learning Credit (education credits) for qualified tuition and related expenses. The proposed regulations provide rules for calculating an education credit and the general eligibility requirements for claiming an education credit. The proposed regulations define what are qualified tuition and related expenses that a taxpayer may use in claiming an education credit. |
| T.D. 8815(PDF, 12K) |
HTML Version(7K) |
1/28/1999 |
| Federal Unemployment Tax Act (FUTA) Taxation of Amounts Under Employee Benefit Plans |
| These final regulations provide guidance on section 3306(r) of the Internal Revenue Code, which deals with FUTA taxes on nonqualified deferred compensation. The regulations are effective January 1, 2000 and affect many businesses, nonprofit organizations, governments, and individuals. The full text of the regulations is in the Federal Register dated January 29, 1999. |
| REG-106564-98(PDF, 15K) |
HTML Version(10K) |
1/27/1999 |
| Modifications & Additions to the Unified Partnership Audit Procedures |
| These temporary, final, and proposed regulations amend and add to the existing administrative procedures that taxpayers and the Service use when the Service audits a partnership under the unified partnership audit rules (also known as the TEFRA rules). These changes apply to the imposition of penalties as part of a partnership audit, the small partnership exception to the TEFRA rules, the impact of a bankrupt tax matters partner on the procedures, and the taxpayer's right to a consistent settlement resolving partnership items. |
| T.D. 8808(PDF, 28K) |
HTML Version(25K) |
1/27/1999 |
| Modifications & Additions to the Unified Partnership Audit Procedures |
| These temporary, final, and proposed regulations amend and add to the existing administrative procedures that taxpayers and the Service use when the Service audits a partnership under the unified partnership audit rules (also known as the TEFRA rules). These changes apply to the imposition of penalties as part of a partnership audit, the small partnership exception to the TEFRA rules, the impact of a bankrupt tax matters partner on the procedures, and the taxpayer's right to a consistent settlement resolving partnership items. |
| REG-115433-98(PDF, 31K) |
HTML Version(29K) |
1/26/1999 |
| Timely Mailing Treated as Timely Filing/Electronic Postmark |
| The IRS has published proposed regulations that extend the timely mailing treated as timely filing rule to electronically filed documents. Currently, a document mailed through the U.S. mail will be treated as filed on the date of the U.S. Postal Service postmark on the envelope if the date of the postmark is on or before the due date for the document and the IRS actually received the document after the due date. The regulations will also make changes to conform to changes made to § 7502 of the Internal Revenue Code since 1960. The full text of the regulations is set forth in the Federal Register dated... |
| REG-116824-98(PDF, 9K) |
HTML Version(5K) |
1/26/1999 |
| Notice & Opportunity for Hearing upon Filing of Notice of Lien |
| The regulation sets forth the IRS procedures for notice to taxpayers of the right to a hearing with respect to the filing of a federal tax lien on or after January 19, 1999. Among other things, the regulation describes how to request a hearing, what can be considered at the hearing, and how to obtain judicial review of a determination resulting from the hearing. The procedures for submitting comments on the regulations, as well as the full text of the regulations, are published in the Federal Register for January 22, 1999. |
| REG-116826-97(PDF, 41K) |
HTML Version(42K) |
1/26/1999 |
| Deduction for Interest on Qualified Education Loans |
| Proposed regulations addressing the deduction for interest paid on qualified education loans. These proposed regulations provide guidance under section 221 with respect to the deduction for interest paid on qualified education loans. If the requirements of the regulations are satisfied, a taxpayer may deduct the amount of interest paid on qualified education loans. The deduction is an adjustment to gross income and, therefore, is available to eligible taxpayers regardless of whether they itemize deductions. The deduction is limited to $1,000 for taxable years beginning in 1998 (increasing to $2,500 for... |
| REG-117620-98(PDF, 9K) |
HTML Version(5K) |
1/26/1999 |
| Notice & Opportunity for Hearing Before Levy |
| The regulation sets forth the IRS procedures for notice to taxpayers of the right to a hearing concerning an IRS levy made on or after January 19, 1999. Among other things, the regulation describes how to request a hearing, what can be considered at the hearing, and how to obtain judicial review of a determination resulting from the hearing. The procedures for submitting comments on the regulations, as well as the full text of the regulations, are published in the Federal Register for January 22, 1999. |
| REG-121806-97(PDF, 9K) |
HTML Version(5K) |
1/26/1999 |
| Disclosure of Return Information to the Bureau of the Census |
| Additions to, and deletions from, the list of items of information disclosed to the Bureau of the Census for use in certain statistical programs. |
| T.D. 8810(PDF, 53K) |
HTML Version(54K) |
1/26/1999 |
| Notice & Opportunity for Hearing upon Filing of Notice of Lien |
| The regulation sets forth the IRS procedures for notice to taxpayers of the right to a hearing with respect to the filing of a federal tax lien on or after January 19, 1999. Among other things, the regulation describes how to request a hearing, what can be considered at the hearing, and how to obtain judicial review of a determination resulting from the hearing. The procedures for submitting comments on the regulations, as well as the full text of the regulations, are published in the Federal Register for January 22, 1999. |
| T.D. 8809(PDF, 57K) |
HTML Version(58K) |
1/26/1999 |
| Notice & Opportunity for Hearing before Levy |
| The regulation sets forth the IRS procedures for notice to taxpayers of the right to a hearing concerning an IRS levy made on or after January 19, 1999. Among other things, the regulation describes how to request a hearing, what can be considered at the hearing, and how to obtain judicial review of a determination resulting from the hearing. The procedures for submitting comments on the regulations, as well as the full text of the regulations, are published in the Federal Register for January 22, 1999. |
| T.D. 8807(PDF, 12K) |
HTML Version(8K) |
1/26/1999 |
| Timely Mailing Treated as Timely Filing/Electronic Postmark |
| The IRS has published temporary regulations that extend the timely mailing treated as timely filing rule to electronically filed documents. Currently, a document mailed through the U.S. mail will be treated as filed on the date of the U.S. Postal Service postmark on the envelope if the date of the postmark is on or before the due date for the document and the IRS actually received the document after the due date. The full text of the regulations is set forth in the Federal Register dated January 15, 1999. |
| T.D. 8811(PDF, 17K) |
HTML Version(11K) |
1/25/1999 |
| Disclosure of Return Information to the Bureau of the Census |
| Section 6103(j) provides that upon written request from the Secretary of Commerce, the Secretary is to furnish to the Bureau of the Census tax return information that is prescribed by Treasury regulations for the purpose of structuring censuses and national economic accounts and conducting related statistical activities. Periodically, the regulations are amended to reflect the changing needs of the Bureau of the Census for statutorily authorized statistical activities. These new temporary and proposed regulations reflect the addition of certain items requested by the Secretary of Commerce to improve... |
| T.D. 8805(PDF, 78K) |
HTML Version(81K) |
1/12/1999 |
| Allocation of Loss with Respect to Stock & Other Personal Property; Application of Section 904 to Income Subject to Separate Limitations |
| These regulations provide rules on whether loss on the sale of personal property reduces U.S.-source or foreign-source income. These rules principally affect the computation of the foreign tax credit limitation. The final and temporary regulations are applicable to loss recognized on or after January 11, 1999. However, taxpayers are permitted to apply the regulations retroactively to losses in all post-1986 taxable years. Further explanation of the regulations and the full text of the regulations can be found in the Federal Register dated January 11, 1999. |
| T.D. 8806(PDF, 18K) |
HTML Version(12K) |
1/12/1999 |
| Employee Stock Ownership Plans; Section 411(d)(6) Protected Benefits (Taxpayer Relief Act of 1997); Qualified Retirement Plan Benefits |
| These final and temporary regulations provide for changes to the rules regarding qualified retirement plan benefits that are protected from reduction by plan amendment. These changes have been made necessary by the Taxpayer Relief Act of 1997 (TRA '97). The final regulations change the existing regulations to conform to the TRA '97 rules regarding in-kind distribution requirements for certain employee stock ownership plans, and specify the time period during which certain plan amendments for which relief has been granted by TRA '97 may be made without violating the prohibition against plan amendments that reduce accrued... |
| T.D. 8800(PDF, 16K) |
HTML Version(12K) |
1/5/1999 |
| Consolidated Returns--Limitation on Recapture of Overall Foreign Loss Accounts |
| Corporations that file consolidated tax returns and claim foreign tax credits must generally keep accounts for certain foreign losses, called consolidated overall foreign loss accounts. These accounts affect the amount of foreign tax credits that a consolidated group is permitted to claim. The temporary regulation permits taxpayers to elect to delay the effective date of certain provisions relating to overall foreign losses. |
| T.D. 8801(PDF, 32K) |
HTML Version(30K) |
1/5/1999 |
| Arbitrage Restrictions on Tax-Exempt Bonds |
| The final regulations provide a safe harbor for issuers of state or local bonds that use the proceeds of those bonds to purchase guaranteed investment contracts or investments for a yield restricted defeasance escrow. If the requirements of the safe harbor are satisfied, the issuer will be deemed to have paid fair market value for its investment. |
| REG-106902-98(PDF, 41K) |
HTML Version(41K) |
1/5/1999 |
| Consolidated Returns -- Consolidated Overall Foreign Losses & Separate Limitation Losses |
| Corporations that file consolidated tax returns and claim foreign tax credits must generally keep accounts for certain foreign losses, called consolidated overall foreign loss accounts. These accounts affect the amount of foreign tax credits that a consolidated group is permitted to claim. The proposed regulation modifies the rules that apply to these accounts when a corporation joins or leaves a consolidated group. |
| REG-106386-98(PDF, 8K) |
HTML Version(4K) |
1/5/1999 |
| Retention of Income Tax Return Preparers' Signatures |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the retention of income tax return preparers' signatures. The text of those temporary regulations also serves as the text of these proposed regulations. |
| T.D. 8803(PDF, 11K) |
HTML Version(8K) |
1/5/1999 |
| Retention of Income Tax Return Preparers' Signatures |
| The IRS has published temporary regulations that permit income tax return preparers to utilize two alternative means of meeting the requirement that a preparer, who chooses to provide a taxpayer with a return or claim for refund with a copy of the preparer's signature, retain the manually signed return or claim for refund. Under the temporary regulations, a preparer may continue to retain the manually signed copy of the return or claim for refund, or in the alternative: 1) retain a photocopy of the return or claim for refund, or 2) use an authorized electronic storage system to store and produce a copy of the return or... |
