| REG-126016-01(PDF, 20K) |
|
12/30/2002 |
| Establishing Defenses to the Imposition of the Accuracy-Related Penalty |
| This document contains proposed regulations that limit the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or fail to disclose that they have taken a position on a return based upon a regulation being invalid. By limiting a taxpayer’s ability to use an opinion or advice from a tax professional as a basis for a defense, the proposed regulations are intended to promote the disclosure of reportable transactions and positions by taxpayers that conflict with regulations issued by the Secretary. |
| REG-150313-01(PDF, 82K) |
|
12/26/2002 |
| Redemptions Taxable as Dividends |
| This document contains proposed regulations that provide guidance regarding the treatment of the basis of redeemed stock when a distribution in redemption of such stock is treated as a dividend, as well as guidance regarding certain acquisitions of stock by related corporations that are treated as distributions in redemption of stock. The proposed regulations affect shareholders whose stock in a corporation is redeemed or is acquired by a corporation related to the issuer of the stock, and are necessary to provide such shareholders with guidance regarding the treatment of the basis of such stock. This document also provides notice of a public hearing on these proposed regulations. |
| T.D. 9034(PDF, 72K) |
|
12/26/2002 |
| Education Tax Credit |
| This document contains final regulations relating to the Hope Scholarship Credit and the Lifetime Learning Credit under section 25A of the Internal Revenue Code. The final regulations reflect changes made to the law by the Taxpayer Relief Act of 1997. These regulations provide guidance to individuals who may claim the Hope Scholarship Credit or the Lifetime Learning Credit for the payment of certain postsecondary educational expenses. |
| T.D. 9033(PDF, 14K) |
|
12/24/2002 |
| Section 6038 - Returns Required with Respect to Controlled Foreign Partnerships |
| This document contains final and temporary regulations relating to controlled foreign partnerships. This document requires that the United States partner must follow the filing requirements that are specified in the instructions for Form 8865. The text of the temporary regulation also serves as the text of the proposed regulation set forth in the Proposed Rules section in this issue of the Federal Register. |
| T.D. 9032(PDF, 76K) |
|
12/23/2002 |
| Election to Treat Trust as Part of an Estate |
| This document contains final regulations under section 645 relating to an election for certain revocable trusts to be treated and taxed as part of an estate. The final regulations provide the procedures and requirements for making the election, rules regarding the tax treatment of the trust and the estate while the election is in effect, and rules regarding the termination of the election. |
| T.D. 9031(PDF, 28K) |
|
12/23/2002 |
| Reduced Maximum Exclusion of Gain from Sale or Exchange of Principal Residence |
| This document contains temporary regulations relating to the exclusion of gain from the sale or exchange of a taxpayer’s principal residence in the case of a taxpayer who has not owned and used the property as the taxpayer’s principal residence for two of the preceding five years or who has excluded gain from the sale or exchange of a principal residence within the preceding two years. |
| T.D. 9030(PDF, 67K) |
|
12/23/2002 |
| Exclusion of Gain from Sale or Exchange of a Principal Residence |
| This document contains final regulations relating to the exclusion of gain from the sale or exchange of a taxpayer’s principal residence. These regulations reflect changes to the law made by the Taxpayer Relief Act of 1997, as amended by the Internal Revenue Service Restructuring and Reform Act of 1998. |
| REG-138882-02(PDF, 12K) |
|
12/23/2002 |
| Reduced Maximum Exclusion of Gain from Sale or Exchange of Principal Residence |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the reduced maximum exclusion available to certain taxpayers who sell or exchange their principal residence but who have not owned and used the property as their principal residence for two years of the preceding five years or who have excluded gain on a previous sale or exchange within the last two years. |
| REG-124069-02(PDF, 14K) |
|
12/20/2002 |
| Section 6038 - Returns required with respect to controlled foreign partnerships |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing a temporary regulation relating to controlled foreign partnerships. That document requires that the United States partner must follow the filing requirements that are specified in the instructions for Form 8865. The text of that regulation also serves as the text of this proposed regulation. This document also provides notice of a public hearing on these proposed regulations. |
| T.D. 9029(PDF, 3K) |
|
12/18/2002 |
| Information Reporting for Qualified Tuition and Related Expenses; Magnetic Media Filing Requirements for Information Returns |
| This document contains final regulations relating to the information reporting requirements for qualified tuition and related expenses under section 6050S of the Internal Revenue Code, including rules prescribing when the required information returns must be filed on magnetic media. The final regulations reflect changes made to the law by the Taxpayer Relief Act of 1997 and the amendments made by the Internal Revenue Service Restructuring and Reform Act of 1998 and Public Law 107-131. |
| REG-125638-01(PDF, 157K) |
|
12/18/2002 |
| Guidance Regarding Deduction and Capitalization of Expenditures |
| This document contains proposed regulations that explain how section 263(a) of the Internal Revenue Code (Code) applies to amounts paid to acquire, create, or enhance intangible assets. This document also contains proposed regulations under section 167 of the Code that provide safe harbor amortization for certain intangible assets, and proposed regulations under section 446 of the Code that explain the manner in which taxpayers may deduct debt issuance costs. Finally, this document provides a notice of public hearing on these proposed regulations. |
| REG-151043-02(PDF, 10K) |
|
12/18/2002 |
| Rents and Royalties |
| This document contains proposed regulations relating to the inclusion in gross income of advance rentals. The proposed regulations authorize the Commissioner to provide rules allowing for the inclusion of advance rentals in gross income in a year other than the year of receipt. The proposed regulations will affect taxpayers that receive advance payments for the use of certain items (such as intellectual property) to be designated by the Commissioner. |
| REG-122380-02(PDF, 14K) |
|
12/18/2002 |
| Regulations Governing Practice Before the Internal Revenue Service |
| This document provides advance notice of proposed rulemaking to amend the regulations governing practice before the Internal Revenue Service, which appear in the Code of Federal Regulations and in pamphlet form as Treasury Department Circular No. 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Service. |
| T.D. 9027(PDF, 17K) |
|
12/17/2002 |
| Levy Restrictions During Installment Agreements |
| This document contains final regulations relating to restrictions on levy during the period that an installment agreement is proposed or in effect. The regulations reflect changes to the law made by the Internal Revenue Service Restructuring and Reform Act of 1998. |
| T.D. 9028(PDF, 41K) |
|
12/17/2002 |
| Third Party Contacts |
| This document contains final regulations providing guidance on third-party contacts made with respect to the determination or collection of tax liabilities. The regulations reflect changes to section 7602 of the Internal Revenue Code made by section 3417 of the Internal Revenue Service Restructuring and Reform Act of 1998. The regulations potentially affect all taxpayers whose Federal tax liabilities are being determined or collected by the IRS. |
| T.D. 9026(PDF, 14K) |
|
12/17/2002 |
| Low-Income Taxpayer Clinics--Definition of Income Tax Return Preparer |
| This document contains final regulations that exclude certain Low-Income Taxpayer Clinics (LITCs) that qualify for grants under section 7526 of the Internal Revenue Code from the definition of income tax return preparer under section 7701(a)(36). These final regulations also exclude certain persons who are employed by, or volunteer for, such clinics. |
| T.D. 9025(PDF, 9K) |
|
12/13/2002 |
| Intercompany Transactions: Conforming Amendments to Section 446 |
| On July 18, 1995, the Treasury Department and the IRS published final regulations governing the intercompany transaction system of the consolidated return regulations. Those regulations state that the timing rules of the intercompany transaction system are a method of accounting. At the time of the publication of those regulations, no amendment was made to the regulations promulgated under section 446 to coordinate with that statement. |
| T.D. 9021(PDF, 35K) |
|
12/3/2002 |
| Loans From a Qualified Employer Plan to Plan Participants or Beneficiaries |
| This document contains final regulations relating to loans made from a qualified employer plan to plan participants or beneficiaries. These final regulations affect administrators of, participants in, and beneficiaries of qualified employer plans that permit participants or beneficiaries to receive loans from plans, including loans from section 403(b) contracts and other contracts issued under qualified employer plans. |
| REG-251003-96(PDF, 103K) |
|
11/27/2002 |
| Statement of Procedural Rules |
| This document amends the Statement of Procedural Rules to reflect changes effected by the Electronic Freedom of Information Act Amendments of 1996, to update organizational titles and addresses, and to make certain changes in the IRS’s procedures for processing Freedom of Information Act requests. The rules affect persons requesting records from the IRS. |
| T.D. 9024(PDF, 11K) |
|
11/27/2002 |
| Liability For Insurance Premium Excise Tax |
| This document contains final regulations under section 4374 relating to liability for the insurance premium excise tax. This document affects persons who make, sign, issue, or sell a policy of insurance, indemnity bond, annuity contract, or policy of reinsurance issued by any foreign insurer or reinsurer. |
| REG-127380-02(PDF, 16K) |
|
11/26/2002 |
| Outbound Liquidations to Foreign Corporations |
| This document contains proposed regulations that provide guidance regarding the application of section 367(e)(2) to certain outbound liquidations. The regulations amend the anti-abuse rule of §1.367(e)-2(d) by narrowing the scope of the rule to apply only to outbound transfers to a foreign corporation in a complete liquidation of a domestic corporation in which a principal purpose of the liquidation is the avoidance of U.S. tax. This document also provides a notice of a public hearing on these proposed regulations. |
| T.D. 9023(PDF, 23K) |
|
11/21/2002 |
| Taxpayer Identification Number Rule Where Taxpayer Claims Treaty Rate and Is Entitled to an Unexpected Payment |
| This document contains final regulations that provide additional guidance needed to comply with the withholding rules under section 1441 and conforming changes to the regulations under section 6109. Specifically, these final regulations provide rules that facilitate compliance by withholding agents where foreign individuals who are claiming reduced rates of withholding under an income tax treaty receive an unexpected payment from the withholding agent and do not possess the required individual taxpayer identification number. |
| REG-143321-02(PDF, 13K) |
|
11/14/2002 |
| Information Reporting Relating to Taxable Stock Transactions |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to information reporting relating to taxable stock transactions. This document contains proposed regulations under section 6043(c) requiring information reporting by a corporation if control of the corporation is acquired or if the corporation has a recapitalization or other substantial change in capital structure. |
| T.D. 9022(PDF, 36K) |
|
11/14/2002 |
| Information Reporting Relating to Taxable Stock Transactions |
| This document contains temporary regulations under section 6043(c) requiring information reporting by a corporation if control of the corporation is acquired or if the corporation has a recapitalization or other substantial change in capital structure. This document also contains temporary regulations under section 6045 concerning information reporting requirements for brokers with respect to transactions described in section 6043(c). The text of these temporary regulations also serves as the text of proposed regulations set forth in the Proposed Rules section of this issue of the Federal Register. |
| REG-141832-02(PDF, 10K) |
|
11/8/2002 |
| Substantiation of Incidental Expenses |
| This document contains proposed amendments to regulations relating to the requirement to substantiate business expenses for traveling expenses away from home. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to the requirement to substantiate business expenses for traveling expenses while away from home under section 274 of the Internal Revenue Code. The text of those regulations also serves as text for these proposed regulations. |
| T.D. 9020(PDF, 11K) |
|
11/8/2002 |
| Substantiation of Incidental Expenses |
| This document contains amendments to regulations relating to the requirement to substantiate business expenses for traveling expenses while away from home. The regulations affect taxpayers who deduct expenses for incidental expenses while traveling away from home. The text of the temporary regulations also serves as text for the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. |
| REG-154920-01(PDF, 26K) |
|
11/6/2002 |
| Guidance Regarding the Definition of Foreign Personal Holding Company Income |
| This document contains proposed regulations that provide that gain or loss arising from certain commodities hedging transactions and currency gain or loss arising from certain interest-bearing liabilities do not constitute (or are not netted against) foreign personal holding company income. This treatment is proposed because the applicable commodities hedging transactions and interest-bearing liabilities typically offset transactions that do not generate foreign personal holding company income. This document also provides notice of a public hearing on these proposed regulations. |
| REG-103777-02(PDF, 25K) |
|
11/5/2002 |
| User Fees for Processing Offers to Compromise |
| This document contains proposed amendments to the regulations relating to user fees to provide for the imposition of user fees for the processing of offers to compromise. The charging of user fees implements the Independent Offices Appropriations Act (IOAA), which is codified at 31 U.S.C. 9701. This document also contains a notice of public hearing on these proposed regulations. |
| T.D. 9019(PDF, 9K) |
|
10/25/2002 |
| Unit Livestock Price Method |
| This document contains final regulations relating to the use of the unit-livestock-price method of accounting. The regulations affect livestock raisers and other farmers that elect to use the unit-livestock-price method. These regulations provide rules relating to the annual reevaluation of unit prices and the depreciation of livestock raised for draft, breeding, or dairy purposes. |
| REG-131478-02(PDF, 88K) |
|
10/18/2002 |
| Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions. |
| This document contains proposed regulations that redetermine the basis of stock of a subsidiary member of a consolidated group immediately prior to certain dispositions and deconsolidations of such stock. In addition, this document contains proposed regulations that suspend certain losses recognized on the disposition of such stock. The regulations apply to corporations filing consolidated returns. |
| T.D. 9017(PDF, 58K) |
|
10/18/2002 |
| Tax Shelter Disclosure Statements |
| These temporary regulations modify the rules relating to the filing by certain taxpayers of a disclosure statement with their Federal tax returns under section 6011(a) and include conforming changes to the rules relating to the registration of confidential corporate tax shelters under section 6111(d). These regulations affect taxpayers participating in reportable transactions and persons responsible for registering confidential corporate tax shelters. |
| REG-103735-00(PDF, 19K) |
|
10/17/2002 |
| Tax Shelter Disclosure Statements |
| These proposed rules provide the public with additional guidance needed to comply with the disclosure rules under section 6011(a). The rules also make conforming changes to the registration requirements under section 6111(d). The proposed rules affect taxpayers participating in certain reportable transactions. |
| REG-103736-00(PDF, 14K) |
|
10/17/2002 |
| Requirement to Maintain a List of Investors in Potentially Abusive Tax Shelters |
| These proposed rules relate to the preparation, maintenance, and furnishing of lists of persons in potentially abusive tax shelters under section 6112. These regulations apply to sellers and organizers, collectively known as material advisors, of potentially abusive tax shelters. In the rules and regulations portion of this issue of the Federal Register, the IRS is issuing temporary regulations modifying the rules relating to the list maintenance requirements under section 6112. |
| T.D. 9018(PDF, 39K) |
|
10/17/2002 |
| Requirement to Maintain a List of Investors in Potentially Abusive Tax Shelters |
| These temporary regulations relate to the preparation, maintenance, and furnishing of lists of persons in potentially abusive tax shelters under section 6112. These regulations apply to organizers and sellers of potentially abusive tax shelters. 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-124667-02(PDF, 53K) |
|
10/4/2002 |
| Disclosure of Relative Values of Optional Forms of Benefit |
| This document contains proposed regulations that would consolidate the content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable under certain retirement plans, and would specify requirements for disclosing the relative value of optional forms of benefit that are payable from certain retirement plans in lieu of a qualified joint and survivor annuity. These regulations would affect retirement plan sponsors and administrators, and participants in and beneficiaries of retirement plans. |
| T.D. 9016(PDF, 70K) |
|
9/23/2002 |
| Obligations of States and Political Subdivisions |
| This document contains final regulations on the definition of private activity bonds applicable to tax-exempt bonds issued by state and local governments for output facilities. These regulations affect issuers of tax-exempt bonds and provide needed guidance for applying the private activity bond restrictions to output facilities. |
| REG-142599-02(PDF, 15K) |
|
9/23/2002 |
| Guidance Regarding Mixed Use Output Facilities |
| This document describes and illustrates rules the IRS and Treasury Department expect to propose in a notice of proposed rulemaking with respect to the issuance of tax-exempt bonds for the government use portion of an output facility that is used for both a government use and a private business use. |
| T.D. 9015(PDF, 11K) |
|
9/9/2002 |
| Designated IRS Officer or Employee Under Section 7602(a)(2) of the Internal Revenue Code |
| This document contains temporary regulations that modify the existing regulations promulgated under section 7602(a) of the Internal Revenue Code relating to administrative summonses. Specifically, these temporary regulations confirm that officers and employees of the Office of Chief Counsel may be included as persons designated to receive summoned books, papers, records, or other data and to take summoned testimony under oath. |
| REG-134026-02(PDF, 8K) |
|
9/9/2002 |
| Designated IRS Officer or Employee Under Section 7602(a)(2) of the Internal Revenue Code |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that modify the existing regulations promulgated under section 7602(a) of the Internal Revenue Code relating to administrative summonses. The temporary regulations confirm that officers and employees of the Office of Chief Counsel may be included as persons designated to receive summoned books, papers, records, or other data and to take summoned testimony under oath. |
| T.D. 9013(PDF, 45K) |
|
8/21/2002 |
| Limitations on Passive Activity Losses & Credits |
| These regulations provide guidance on the treatment of self-charged items of income and expense under section 469. The regulations recharacterize a percentage of certain portfolio income and expense as passive income and expense (self-charged items) when a taxpayer engages in a lending transaction with a partnership or an S corporation (passthrough entity) in which the taxpayer owns a direct or indirect interest and the loan proceeds are used in a passive activity. |
| T.D. 9014(PDF, 12K) |
|
8/14/2002 |
| Furnishing Identifying Number of Income Tax Return Preparer |
| This document contains final regulations that allow income tax return preparers to elect an alternative to their social security number for purposes of identifying themselves on returns they prepare. The regulations are needed to implement section 6109(a) as amended by the Internal Revenue Service Restructuring and Reform Act of 1998. |
| REG-208280-86(PDF, 176K) |
|
8/2/2002 |
| Exclusions From Gross Income of Foreign Corporations |
| Exclusions From Gross Income of Foreign Corporations: This proposed rule explains when a foreign corporation engaged in the international operation of a ship or ships or aircraft may exempt its U.S. source income from U.S. Federal income tax. The rule applies to a corporation organized in a foreign country that grants a reciprocal exemption to U.S. corporations, if the foreign corporation satisfies certain ownership requirements. |
| REG-133254-02(PDF, 28K) |
|
8/2/2002 |
| Guidance on Reporting of Deposit Interest Paid to Nonresident Aliens |
| This document contains proposed regulations that provide guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals that are residents of certain specified countries. These proposed regulations affect persons making payments of interest with respect to such deposits. This document also provides a notice of public hearing on these proposed regulations and withdraws the notice of proposed rulemaking |
| T.D. 9012(PDF, 16K) |
|
8/1/2002 |
| Clarification of Entity Classification Rules |
| This document contains final regulations under section 7701 that address the Federal tax classification of a business entity wholly owned by a foreign government and that also provide that a nonbank entity wholly owned by a foreign bank cannot be disregarded as an entity separate from its owner (disregarded entity) for purposes of applying the special rules applicable to banks under the Internal Revenue Code. |
| REG-106879-00(PDF, 22K) |
|
8/1/2002 |
| Dual Consolidated Loss Recapture Events |
| This document contains proposed regulations under section 1503(d) regarding the events that require the recapture of dual consolidated losses. These regulations are issued to facilitate compliance by taxpayers with the dual consolidated loss provisions. The proposed regulations generally provide that certain events will not trigger recapture of a dual consolidated loss or payment of the associated interest charge. |
| REG-112306-00(PDF, 76K) |
|
7/31/2002 |
| Corel Office Document |
| This document contains procedures for certain United States persons holding marketable stock in a passive foreign investment company (PFIC) to elect mark to market treatment for that stock under section 1296 and related provisions of sections 1291 and 1295. These proposed regulations affect United States persons owning marketable stock in a PFIC. This document also provides notice of a public hearing on these proposed regulations. |
| REG-106359-02(PDF, 47K) |
|
7/29/2002 |
| Compensatory Stock Options Under Section 482 |
| This document contains proposed regulations that provide guidance regarding the application of the rules of section 482 governing qualified cost sharing arrangements. These proposed regulations provide guidance regarding the treatment of stock-based compensation for purposes of the rules governing qualified cost sharing arrangements and for purposes of the comparability factors to be considered under the comparable profits method. |
| T.D. 9011(PDF, 135K) |
|
7/26/2002 |
| Regulations Governing Practice Before the Internal Revenue Service |
| This document contains final regulations governing practice before the Internal Revenue Service (Circular 230). These regulations affect individuals who are eligible to practice before the Internal Revenue Service. These regulations modify the general standards of practice before the Internal Revenue Service. |
| REG-106876-00(PDF, 56K) |
|
7/26/2002 |
| Revision of Income Tax Regulations under Sections 897, 1445, and 6109 |
| This document contains proposed regulations to require the use of taxpayer identifying numbers on submissions under sections 897 and 1445. The proposed regulations are necessary to properly identify foreign taxpayers for which submissions are made for the reduction or elimination of tax under sections 897 and 1445. The proposed regulations also address miscellaneous items, such as the amendment to section 1445(e)(3) under the Small Business Job Protection Act of 1996. |
| T.D. 9010(PDF, 44K) |
|
7/26/2002 |
| Information Reporting Requirements for Certain Payments Made on Behalf of Another Person |
| This document contains regulations under section 6041 that provide information reporting requirements for escrow agents and other persons making payments on behalf of another person, clarify who is the payee for information reporting purposes if a check or other instrument is made payable to joint payees, and clarify the amount to be reported. |
| T.D. 9008(PDF, 38K) |
|
7/23/2002 |
| Guidance Under Subpart F Relating to Partnerships |
| This document contains final regulations providing guidance under subpart F relating to partnerships. The final regulations are necessary in order to clarify the treatment of a controlled foreign corporation’s (CFC) distributive share of partnership income under subpart F. The final regulations will affect United States shareholders of CFCs that have an interest in a partnership. |
| T.D. 9009(PDF, 29K) |
|
7/23/2002 |
| Taxable Years of Partner and Partnership |
| This document contains final regulations on the taxable year of a partnership with foreign partners and tax-exempt partners. The final regulations provide that in certain circumstances the taxable year of a partnership will be determined without regard to the taxable year of certain foreign partners and certain tax-exempt partners. |
| REG-115781-01(PDF, 22K) |
|
7/23/2002 |
| Definition of Guaranteed Annuity & Lead Unitrust Interests |
| This document contains proposed regulations conforming the income, gift, and estate tax regulations to the Tax Court's decision in Estate of Boeshore v. Commissioner, 78 T.C. 523 (1982), acq. in result, 1987-2 C.B. 1, holding portions of §20.2055-2(e)(2)(vi)(e) of the Estate Tax Regulations invalid. |
| REG-124256-02(PDF, 28K) |
|
7/23/2002 |
| Earnings Calculation for Returned or Recharacterized IRA Contributions |
| These proposed regulations provide a new method to be used for calculating the net income attributable to IRA contributions that are distributed as a returned contribution pursuant to section 408(d)(4) of the Internal Revenue Code or recharacterized pursuant to section 408A(d)(6). The regulations will affect IRA owners and IRA trustees, custodians and issuers. |
| T.D. 9007(PDF, 47K) |
|
7/23/2002 |
| Compromise of Tax Liabilities |
| This document contains final regulations relating to the compromise of internal revenue taxes. The regulations adopt the rules of the temporary regulations and reflect changes to the law made by the Internal Revenue Service Restructuring and Reform Act of 1998 and the Taxpayer Bill of Rights 2. |
| REG-123345-01(PDF, 16K) |
|
7/22/2002 |
| Net Gift Treatment under Section 2519 |
| This document contains proposed amendments to the regulations relating to the amount treated as a transfer under section 2519 of the Internal Revenue Code when there is a right to recover gift tax under section 2207A(b) and the related gift tax consequences if the right to recover the gift tax is not exercised. The proposed regulations will affect donee spouses who make lifetime dispositions of all or part of a qualifying income interest in qualified terminable interest property. |
| T.D. 9005(PDF, 17K) |
|
7/22/2002 |
| Refund of Mistaken Contributions & Withdrawal Liability Payments |
| This document provides final regulations relating to the return of employer contributions or withdrawal liability payments made to multiemployer plans due to a mistake of fact or law. Changes to the applicable laws were made by the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). The final regulations provide guidance to the public in complying with MPPAA. The regulations affect multiemployer plans which receive mistaken contributions or withdrawal liability payments. |
| T.D. 9006(PDF, 27K) |
|
7/19/2002 |
| Notice to Interested Parties |
| This document contains final regulations relating to the notice to interested parties requirement. Before the IRS can issue an advance determination regarding the qualification of a retirement plan, a plan sponsor must provide evidence that it has notified all persons who qualify as interested parties that an application for an advance determination will be filed with the IRS. |
| T.D. 9004(PDF, 26K) |
|
7/19/2002 |
| Real Estate Mortgage Investment Conduits |
| This document contains final regulations relating to safe harbor transfers of noneconomic residual interests in real estate mortgage investment conduits (REMICs). The final regulations provide additional limitations on the circumstances under which transferors may claim safe harbor treatment. |
| T.D. 9003(PDF, 128K) |
|
7/18/2002 |
| Relief From Joint and Several Liability |
| This document contains final regulations relating to relief from joint and several liability under section 6015 of the Internal Revenue Code. The regulations reflect changes in the law made by the Internal Revenue Service Restructuring and Reform Act of 1998 and by the Community Renewal Tax Relief Act of 2000. The regulations provide guidance to married individuals filing joint returns who seek relief from joint and several liability. |
| T.D. 8999(PDF, 44K) |
|
7/17/2002 |
| Treaty Guidance Regarding Payments with Respect to Domestic Reverse Hybrid Entities |
| This document contains final regulations under section 894 relating to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. law but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (domestic reverse hybrid entities). The regulations affect the determination of tax treaty benefits with respect to U.S. source income of foreign persons. |
| REG-165868-01(PDF, 83K) |
|
7/11/2002 |
| 10 or More Employer Plans |
| This document contains proposed regulations that provide guidance regarding whether a welfare benefit fund is part of a 10 or more employer plan. The regulations reflect changes to the law made by the Deficit Reduction Act of 1984. The regulations will affect certain employers that provide welfare benefits to employees through a plan to which more than one employer contributes. This document also provides notice of a public hearing on these proposed regulations. |
| T.D. 8997(PDF, 21K) |
|
7/9/2002 |
| Carryback of Consolidated Net Operating Losses to Separate Return Years |
| This document contains regulations under section 1502 that affect corporations filing consolidated returns. These regulations permit certain acquiring consolidated groups to elect to waive all or a portion of the pre-acquisition portion of the 5-year carryback period under section 172(b)(1)(H) for certain losses attributable to certain acquired members. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. |
| REG-113910-98(PDF, 7K) |
|
7/3/2002 |
| Special Rules Regarding the Simplified Production & Resale Methods with Historic Absorption Ratio Election. |
| This document withdraws the notice of proposed rulemaking requiring that a historic absorption ratio used with either the simplified production or simplified resale methods be recalculated when the ratio becomes materially inaccurate that was published in the FEDERAL REGISTER on May 24, 1999. The withdrawal is in response to written comments received, oral comments presented at a public hearing and an internal IRS survey. |
| REG-116644-01(PDF, 19K) |
|
7/3/2002 |
| Receipt of Multiple Notices with Respect to Incorrect Taxpayer Identification Numbers |
| This document contains proposed regulations relating to backup withholding. The regulations clarify the method of determining whether the payor has received two notices that a payee’s taxpayer identification number (TIN) is incorrect. If a payor receives two or more such notices with respect to the same account during a three-year period, the payor must begin backup withholding unless the payee provides verification of its correct TIN pursuant to the regulations. |
| T.D. 9002(PDF, 48K) |
|
6/28/2002 |
| Agent for Consolidated Group |
| This document contains final regulations regarding the agent for subsidiaries of an affiliated group that files a consolidated return (agent for the group). The regulations address certain issues concerning the scope of the common parent’s authority, as well as questions concerning the agent for the group when the common parent’s existence terminates. These regulations affect all consolidated groups. |
| REG-209114-90(PDF, 166K) |
|
6/21/2002 |
| Golden Parachute Payments |
| This document contains proposed regulations relating to golden parachute payments to provide guidance to taxpayers who must comply with section 280G. Proposed regulations under section 280G were previously published in the Federal Register on May 5, 1989 (the 1989 proposed regulations). These proposed regulations are proposed to apply to any payments that are contingent on a change in ownership or control occurring on or after January 1, 2004. Taxpayers may rely on these proposed regulations until the effective date of the final regulations. Alternatively, taxpayers may rely on the 1989 regulations for any payment contingent on a change in ownership or control that occurs prior to January 1, 2004. |
| REG-106871-00(PDF, 629K) |
|
6/20/2002 |
| Reporting for Widely Held Fixed Investment Trusts |
| This document contains the withdrawal of proposed regulations (REG-209813-96), published on August 13, 1998 in the Federal Register (63 FR 43354). This document also contains new proposed regulations that define widely held fixed investment trusts, clarify the reporting obligations of the trustees of these trusts and the middlemen connected with these trusts, and provide for the communication of necessary tax information to beneficial owners of trust interests. |
| T.D. 9001(PDF, 77K) |
|
6/19/2002 |
| Disclosure of Return Information to Officers & Employees of the Department of Agriculture for Certain Statistical Purposes and Related Activities |
| This contains a final regulation relating to return information to be disclosed to the Department of Agriculture (Department) for use in conducting the Census of Agriculture. The regulation provides for the disclosure of an additional item of return information to the Department. The regulation provides guidance to IRS personnel responsible for disclosing the return information. |
| REG-248110-96(PDF, 128K) |
|
6/19/2002 |
| Guidance Under Section 817A Regarding Modified Guaranteed Contracts |
| This document contains proposed regulations affecting insurance companies that define the interest rate to be used with respect to certain insurance contracts that guarantee higher returns for an initial, temporary period. Specifically, the proposed regulations define the appropriate interest rate to be used in the determination of tax reserves and required interest for certain modified guaranteed contracts. The proposed regulations also address how temporary guarantee periods that extend past the end of a taxable year are to be taken into account. |
| T.D. 9000(PDF, 32K) |
|
6/18/2002 |
| Modification of Tax Shelter Rules III |
| These regulations modify the rules relating to the filing by certain taxpayers of a statement with their Federal income tax returns under section 6011(a) and the registration of confidential corporate tax shelters under section 6111(d). These rules also affect the list maintenance requirement under section 6112. These regulations affect taxpayers participating in certain reportable transactions, persons responsible for registering confidential corporate tax shelters, and persons responsible for maintaining lists of investors in potentially abusive tax shelters. |
| REG-107524-00(PDF, 30K) |
|
6/13/2002 |
| Guidance Under Section 6050P Regarding Cancellation of Indebtedness |
| This document contains proposed regulations relating to the information reporting requirement under section 6050P of the Internal Revenue Code (Code) for cancellation of indebtedness. The proposed regulations reflect the enactment of section 6050P(c)(2)(D) by the Ticket to Work and Work Incentives Improvement Act of 1999. Section 6050P(c)(2)(D) requires organizations a significant trade or business of which is the lending of money to report discharges of indebtedness. |
| REG-115285-01(PDF, 13K) |
|
6/11/2002 |
| Low-Income Taxpayer Clinics --Definition of Income Tax Return Preparer |
| This document contains proposed regulations that exclude certain Low-Income Taxpayer Clinics (LITCs) that qualify for grants under section 7526 of the Internal Revenue Code from the definition of income tax return preparer under section 7701(a)(36). These proposed regulations also exclude certain persons who are employed by, or volunteer for, such clinics. |
| REG-103829-99(PDF, 24K) |
|
6/6/2002 |
| Excise Taxes; Definition of Highway Vehicle |
| This document contains proposed rules relating to the definition of a highway vehicle for purposes of various excise taxes. The regulations affect vehicle manufacturers, dealers, and lessors; tire manufacturers; sellers and buyers of certain motor fuels; and operators of heavy highway vehicles. |
| T.D. 8993(PDF, 21K) |
|
6/6/2002 |
| Debt Instruments with Original Issue Discount; Annuity Contracts |
| This document contains final regulations relating to the federal income tax treatment of annuity contracts issued by certain insurance companies. The regulations provide guidance on whether certain annuity contracts are excluded from the definition of a debt instrument under the original issue discount provisions of the Internal Revenue Code. |
| T.D. 8998(PDF, 28K) |
|
5/31/2002 |
| Loss Limitation Rules |
| This document contains amendments to temporary regulations issued under sections 337(d) and 1502. The amendments clarify certain aspects of the temporary regulations relating to the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group. The amendments in these temporary regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. |
| REG-103823-99(PDF, 186K) |
|
5/31/2002 |
| Guidance on Cost Recovery Under the Income Forecast Method |
| This document contains proposed regulations relating to deductions available to taxpayers using the income forecast method of depreciation under section 167(g). These proposed regulations reflect changes to the law made by the Small Business Job Protection Act of 1996 and the Taxpayer Relief Act of 1997 and affect taxpayers that produce, own, or license films, videos, sound recordings, books, copyrights, patents, and certain other similar properties. |
| REG-122564-02(PDF, 21K) |
|
5/31/2002 |
| Carryback of Consolidated Net Operating Losses to Separate Return Years |
| This document contains proposed regulations under section 1502 that affect corporations filing consolidated returns. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations permitting certain acquiring consolidated groups to elect to waive all or a portion of the pre-acquisition portion of the 5-year carryback period under section 172(b)(1)(H) for certain losses attributable to certain acquired members. |
| REG-123305-02(PDF, 14K) |
|
5/31/2002 |
| Loss Limitation Rules |
| This document contains proposed amendments to temporary regulations issued under sections 337(d) and 1502. The amendments clarify certain aspects of the temporary regulations relating to the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group. The proposed amendments in these proposed regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. |
| REG-161424-01(PDF, 70K) |
|
5/30/2002 |
| Information Reporting for Qualified Tuition & Related Expenses |
| This document withdraws in part proposed regulations relating to the information reporting requirements under section 6050S. This document also contains new proposed regulations relating to the information reporting requirements under section 6050S for qualified tuition and related expenses. These proposed regulations reflect changes to the law made by the Taxpayer Relief Act of 1997 and the amendments made by the Internal Revenue Service Restructuring and Reform Act of 1998 and Public Law 107-131. The regulations provide guidance to eligible educational institutions that enroll any individual for any academic period. The regulations also provide guidance to insurers that make reimbursements or refunds of qualified tuition and related expenses. This document provides notice of a public hearing on these proposed regulations. |
| T.D. 8992(PDF, 40K) |
|
5/30/2002 |
| Information Reporting for Payments of Interest on Qualified Education Loans |
| This document contains regulations relating to the information reporting requirements under section 6050S for payments of interest on qualified education loans, including the filing of information returns on magnetic media. The final regulations reflect changes to the law made by the Taxpayer Relief Act of 1997. The regulations provide guidance to payees receiving interest payments on qualified education loans. |
| T.D. 8987(PDF, 293K) |
|
5/21/2002 |
| Required Distributions from Retirement Plans |
| This document contains final and temporary regulations relating to required minimum distributions from qualified plans, individual retirement plans, deferred compensation plans under section 457, and section 403(b) annuity contracts, custodial accounts, and retirement income accounts. These regulations will provide the public with guidance necessary to comply with the law and will affect administrators of, participants in, and beneficiaries of qualified plans; institutions that sponsor and individuals who administer individual retirement plans, individuals who use individual retirement plans for retirement income, and beneficiaries of individual retirement plans; and employees for whom amounts are contributed to section 403(b) annuity contracts, custodial accounts, or retirement income accounts and beneficiaries of such contracts and accounts. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of the Federal Register . |
| REG-136193-01(PDF, 138K) |
|
5/21/2002 |
| Notice of Significant Reduction in the Rate of Future Benefit Accrual |
| This document contains proposed regulations relating to the requirements of section 4980F of the Internal Revenue Code (Code) and section 204(h) of the Employee Retirement Income Security Act of 1974 (ERISA), as amended, which apply to defined benefit plans and to individual account plans that are subject to the funding standards of section 412 of the Code and section 302 of ERISA. These regulations provide guidance on the requirements for plan administrators to give notice of plan amendments to adversely affected plan participants and other parties when those amendments provide for a significant reduction in the rate of future benefit accrual or the elimination or significant reduction in an early retirement benefit or retirement-type subsidy. These regulations will affect retirement plan sponsors and administrators, participants in and beneficiaries of retirement plans, and employee organizations representing retirement plan participants. This document also provides a notice of public hearing on these proposed regulations. |
| REG-126024-01(PDF, 49K) |
|
5/17/2002 |
| 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 (1997 Act). The regulations will affect attorneys who receive payments of gross proceeds on behalf of their clients and certain payors (for example, defendants in lawsuits and their insurance companies and agents) that, in the course of their trades or businesses, make payments to these attorneys. |
| T.D. 8996(PDF, 111K) |
|
5/17/2002 |
| Changes in Accounting Periods |
| This document contains final regulations relating to certain adoptions, changes, and retentions of annual accounting periods. The final regulations are necessary to update, clarify, and reorganize the rules and procedures for adopting, changing, and retaining a taxpayer’s annual accounting period. The final regulations primarily affect taxpayers that want to adopt an annual accounting period under section 441 or that must receive approval from the Commissioner to adopt, change, or retain their annual accounting periods under section 442. |
| REG-106457-00(PDF, 21K) |
|
5/16/2002 |
| Diesel Fuel; Blended Taxable Fuel |
| This document contains proposed regulations relating to the tax on diesel fuel and the tax on blended taxable fuel. These regulations affect persons that remove, enter, or sell diesel fuel or remove or sell blended taxable fuel. |
| T.D. 8995(PDF, 70K) |
|
5/15/2002 |
| Mid-contract Change in Taxpayer |
| This document contains final regulations concerning a mid-contract change in taxpayer of a contract accounted for under a long-term contract method of accounting. A taxpayer that is a party to such a contract will be affected by these regulations. |
| T.D. 8994(PDF, 140K) |
|
5/14/2002 |
| Electing Small Business Trust |
| This document contains final regulations relating to the qualification and treatment of electing small business trusts (ESBTs). The final regulations interpret the rules added to the Internal Revenue Code (Code) by section 1302 of the Small Business Job Protection Act of 1996, section 1601 of the Taxpayer Relief Act of 1997, and section 316 of the Community Renewal Tax Relief Act of 2000. |
| T.D. 8985(PDF, 73K) |
|
5/13/2002 |
| Hedging Transactions |
| This document contains final regulations relating to the character of gain or loss from hedging transactions. The regulations reflect changes to the law made by the Ticket to Work and Work Incentives Improvement Act of 1999. The regulations affect businesses entering into hedging transactions. |
| REG-105885-99(PDF, 294K) |
|
5/8/2002 |
| Compensation Deferred under Eligible Deferred Compensation Plans |
| This document contains proposed regulations that would provide guidance on compensation deferred under eligible section 457(b) deferred compensation plans of state and local governmental and tax-exempt entities. The regulations reflect the changes made to section 457 by the Tax Reform Act of 1986, the Small Business Job Protection Act of 1996, the Taxpayer Relief Act of 1997, the Economic Growth and Tax Relief Reconciliation Act of 2001, the Job Creation and Worker Assistance Act of 2002, and other legislation. |
| T.D. 8990(PDF, 39K) |
|
4/29/2002 |
| Equity Options with Flexible Terms; Qualified Covered Call Treatment |
| This document contains final regulations providing guidance on the application of the rules governing qualified covered calls. The new rules address concerns that were created by the introduction of new financial instruments several years after the enactment of the qualified covered call rules. The final regulations provide guidance to taxpayers writing equity call options. |
| T.D. 8988(PDF, 136K) |
|
4/26/2002 |
| Guidance under Section 355(e) |
| This document contains temporary regulations relating to recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition. Changes to the applicable law were made by the Taxpayer Relief Act of 1997. These temporary regulations affect corporations and are necessary to provide them with guidance needed to comply with these changes. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. |
| REG-163892-01(PDF, 19K) |
|
4/26/2002 |
| Guidance under Section 355(e); Recognition of Gain on Certain Distributions of Stock or Securities in Connection with an Acquisition. |
| This document withdraws the notice of proposed rulemaking published in the Federal Register on January 2, 2001. In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations relating to recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition. The text of those regulations also serves as the text of these proposed regulations. |
| T.D. 8991(PDF, 78K) |
|
4/25/2002 |
| Taxation of Tax-Exempt Organizations' Income From Corporate Sponsorship |
| This document contains final regulations relating to the tax treatment of corporate sponsorship payments received by tax-exempt organizations. The final regulations affect exempt organizations that receive sponsorship payments. |
| REG-107184-00(PDF, 14K) |
|
4/24/2002 |
| Guidance Necessary to Facilitate Electronic Tax Administration |
| The IRS is proposing regulations designed to eliminate regulatory impediments to the electronic filing of the Form 1040, A U.S. Individual Income Tax Return. The text of the temporary regulations published in the Rules and Regulations section of this issue of the Federal Register also serves as the text of these proposed regulations. These regulations generally affect taxpayers who file Form 1040 electronically and who are required to file any of the following forms: Form 56, A Notice Concerning Fiduciary Relationship; Form 2120, A Multiple Support Declaration; Form 2439, A Notice to Shareholder of Undistributed Long-Term Capital Gains; Form 3468, A Investment Credit; and Form T (Timber), A Forest Activities Schedules. |
| T.D. 8989(PDF, 34K) |
|
4/24/2002 |
| Guidance Necessary to Facilitate Electronic Tax Administration |
| This document contains regulations designed to eliminate regulatory impediments to the electronic filing of Form 1040, A U.S. Individual Income Tax Return. These regulations generally affect taxpayers who file Form 1040 electronically and who are required to file any of the following forms: Form 56, A Notice Concerning Fiduciary Relationship; Form 2120, A Multiple Support Declaration; Form 2439, A Notice to Shareholder of Undistributed Long-Term Capital Gains; Form 3468, A Investment Credit; and Form T (Timber), A Forest Activities Schedules. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. |
| REG-104762-00(PDF, 27K) |
|
4/17/2002 |
| Levy Restrictions During Installment Agreements |
| This document contains proposed regulations relating to restrictions on levy during the period that an installment agreement is proposed or in effect. The proposed regulations reflect changes to the law made by the Internal Revenue Service Restructuring and Reform Act of 1998. |
| REG-105369-00(PDF, 34K) |
|
4/17/2002 |
| Arbitrage and Private Activity Restrictions Applicable to Tax-exempt Bonds Issued by State and Local Governments; Investment-type Property (prepayment); Private Loan (prepayment). |
| This document contains proposed amendments to the final regulations on the arbitrage and private activity restrictions applicable to tax-exempt bonds issued by State and local governments. The proposed amendments affect issuers of tax-exempt bonds and provide guidance on the definitions of investment-type property and private loan to help issuers comply with the arbitrage and private activity restrictions. This document also provides notice of a public hearing on these proposed regulations. |
| REG-108697-02(PDF, 11K) |
|
4/17/2002 |
| Required Distributions from Retirement Plans |
| In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance concerning required minimum distributions for defined benefit plans and annuity contracts providing benefits under qualified plans, individual retirement plans, and section 403(b) contracts. The regulations will provide the public with guidance necessary to comply with the law and will affect administrators of, participants in, and beneficiaries of qualified plans; institutions that sponsor and individuals who administer individual retirement plans, individuals who use individual retirement plans for retirement income, and beneficiaries of individual retirement plans; and employees for whom amounts are contributed to section 403(b) annuity contracts, custodial accounts, or retirement income accounts and beneficiaries of such contracts and accounts. The text of those temporary regulations also serves as the text of these proposed regulations. |
| REG-165706-01(PDF, 20K) |
|
4/10/2002 |
| Obligations of States and Political Subdivisions |
| This document contains proposed regulations on the definition of refunding issue applicable to tax-exempt bonds issued by States and local governments. This document provides a notice of public hearing on these proposed regulations. |
| REG-112991-01(PDF, 98K) |
|
4/5/2002 |
| Credit for Increasing Research Activities |
| This document contains proposed regulations relating to the computation of the research credit under section 41(c) and the definition of qualified research under section 41(d). In addition, this document contains proposed regulations describing when computer software that is developed by (or for the benefit of) a taxpayer primarily for the taxpayer's internal use is excepted from the internal-use software exclusion contained in section 41(d)(4)(E). These proposed regulations reflect changes to section 41 made by the Tax Reform Act of 1986, the Revenue Reconciliation Act of 1989, the Small Business Job Protection Act of 1996, the Taxpayer Relief Act of 1997, the Tax and Trade Relief Extension Act of 1998, and the Tax Relief Extension Act of 1999. This document also provides notice of a public hearing on these proposed regulations. |
| REG-167648-01(PDF, 12K) |
|
3/29/2002 |
| Amendments to Rules for Determination of Basis of Partner's Interest; Special Rules |
| This document contains proposed regulations relating to special rules on determination of basis of a partner's interest under section 705. The proposed regulations are necessary to coordinate sections 705 and 1032. |
| T.D. 8986(PDF, 29K) |
|
3/29/2002 |
| Determination of Basis of Partner's Interest; Special Rules |
| This document contains final regulations relating to special rules on determination of basis of a partner's interest under section 705 of the Internal Revenue Code. The final regulations are necessary to coordinate sections 705 and 1032. |
| REG-102740-02(PDF, 18K) |
|
3/12/2002 |
| Loss Limitation Rules |
| This document contains proposed regulations under sections 337(d) and 1502 of the Internal Revenue Code. These regulations permit certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. The text of the temporary regulations published 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-118861-00(PDF, 118K) |
|
3/12/2002 |
| Application of Section 338 to Insurance Companies |
| This document contains proposed regulations that apply to a deemed sale or acquisition of an insurance company's assets pursuant to an election under section 338 of the Internal Revenue Code, to a sale or acquisition of an insurance trade or business subject to section 1060, and to the acquisition of insurance contracts through assumption reinsurance. It also contains proposed regulations under section 381 concerning the effect of certain corporate liquidations and reorganizations on certain tax attributes of insurance companies. The proposed regulations apply to insurance companies and to corporations selling and purchasing stock of insurance companies. This document also provides a notice of public hearing on the proposed regulations. |
| REG-107366-00(PDF, 55K) |
|
3/9/2002 |
| Civil Cause of Action for Damages Caused by Unlawful Tax Collection Actions, Including Actions Taken in Violation of Section 362 or Section 524 of the Bankruptcy Code |
| This document contains proposed regulations relating to civil causes of action for damages caused by unlawful collection actions of officers and employees of the IRS and the awarding of costs and certain fees. The proposed regulations reflect amendments made by the Taxpayer Bill of Rights 2 and the Internal Revenue Service Restructuring and Reform Act of 1998. The proposed regulations affect all persons who suffer damages caused by unlawful collection actions of officers or employees of the IRS. |
| REG-251502-96(PDF, 6K) |
|
3/9/2002 |
| Civil Cause of Action for Certain Unauthorized Collection Actions |
| This document withdraws the notice of proposed rulemaking relating to Internal Revenue Code section 7433 that was published in the Federal Register on Wednesday, December 31, 1997. The proposed regulations implemented provisions of the Taxpayer Bill of Rights 2 (TBOR2). TBOR2 raised the cap on damages under section 7433 and eliminated the jurisdictional prerequisite requiring a taxpayer to exhaust administrative remedies before filing a civil damage action. |
| T.D. 8984(PDF, 59K) |
|
3/7/2002 |
| Loss Limitation Rules |
| This document contains regulations under sections 337(d) and 1502. These regulations permit certain losses recognized on sales of subsidiary stock by members of a consolidated group. These regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register . |
| T.D. 8983(PDF, 12K) |
|
2/6/2002 |
| Time for Eligible Air Carriers to File the Third Calendar Quarter 2001 Form 720 |
| This document contains final regulations relating to the time for eligible air carriers reporting air transportation excise taxes to file Form 720, "Quarterly Federal Excise Tax Return," for the third calendar quarter of 2001. These regulations affect certain air carriers. |
| REG-125626-01(PDF, 15K) |
|
2/5/2002 |
| Unit Livestock Price Method |
| This document contains proposed regulations relating to the use of the unit-livestock-price method of accounting. The proposed regulations affect livestock raisers and other farmers that elect to use the unit-livestock-price method. These proposed regulations provide rules relating to the annual reevaluation of unit prices and the depreciation of livestock raised for draft, breeding, or dairy purposes. This document also provides notice of a public hearing on these proposed regulations. |
| REG-120135-01(PDF, 12K) |
|
2/5/2002 |
| Definition of Agent for Certain Purposes |
| This document contains proposed regulations relating to the definition of agent for certain purposes. The proposed regulations clarify that the term agent in certain provisions of section 6103 of the Internal Revenue Code includes contractors. |
| T.D. 8982(PDF, 18K) |
|
2/1/2002 |
| Definition of Disqualified Person |
| This document contains final regulations narrowing the definition of the term disqualified person for section 1031 like-kind exchanges. The amendments in the regulations are in response to recent changes in the federal banking law, especially the repeal of section 20 of the Banking Act of 1933 (commonly referred to as the Glass-Steagall Act). The regulations will affect the eligibility of certain persons to serve as escrow holders of qualified escrow accounts, trustees of qualified trusts, and qualified intermediaries. |
| T.D. 8981(PDF, 56K) |
|
1/29/2002 |
| Disallowance of Deductions and Credits for Failure to File Timely Return |
| This document contains regulations relating to the disallowance of deductions and credits for nonresident alien individuals and foreign corporations that fail to file a timely U.S. income tax return. The current regulations permit nonresident aliens and foreign corporations the benefit of deductions and credits only if they timely file a U.S. income tax return in accordance with subtitle F of the Internal Revenue Code, unless the Commissioner waives the filing deadlines. The temporary regulations revise the waiver standard. 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-107100-00(PDF, 23K) |
|
1/29/2002 |
| Disallowance of Deductions and Credits for Failure to File Timely Return |
| This document contains proposed regulations relating to the disallowance of deductions and credits for nonresident alien individuals and foreign corporations that fail to file a timely U.S. income tax return. The current regulations permit nonresident aliens and foreign corporations the benefit of deductions and credits only if they timely file a U.S. income tax return in accordance with subtitle F of the Internal Revenue Code, unless the Commissioner waives the filing deadlines. The temporary regulations revise the waiver standard. |
| T.D. 8978(PDF, 229K) |
|
1/23/2002 |
| Excise Taxes on Excess Benefit Transactions |
| This document contains final regulations relating to the excise taxes on excess benefit transactions under section 4958 of the Internal Revenue Code, as well as certain amendments and additions to existing Income Tax Regulations affected by section 4958. Section 4958 was enacted by the Taxpayer Bill of Rights 2. Section 4958 imposes excise taxes on any transaction that provides excess economic benefits to a person in a position to exercise substantial influence over the affairs of a public charity or a social welfare organization. |
| REG-115054-01(PDF, 35K) |
|
1/19/2002 |
| Treatment of Community Income for Certain Individuals not Filing Joint Returns |
| This document contains proposed regulations relating to the treatment of community income under section 66 for certain married individuals in community property states who do not file joint individual Federal income tax returns. The regulations also reflect changes in the law made by the Internal Revenue Service Restructuring and Reform Act of 1998. |
| T.D. 8980(PDF, 66K) |
|
1/18/2002 |
| Notice and Opportunity for Hearing before Levy |
| This document contains final regulations relating to the provision of notice to taxpayers of a right to a hearing before levy. The regulations implement certain changes made by section 3401 of the Internal Revenue Service Restructuring and Reform Act of 1998. They affect taxpayers against whose property or rights to property the Internal Revenue Service (IRS) intends to levy. |
| T.D. 8979(PDF, 79K) |
|
1/18/2002 |
| Notice and Opportunity for Hearing upon Filing of Notice of Lien |
| This document contains final regulations relating to the provision of notice to taxpayers of the filing of a notice of federal tax lien (NFTL). A taxpayer receiving notice of a NFTL may request a hearing with IRS Office of Appeals and may subsequently seek judicial review of Appeals' determination. The regulations implement certain changes made by section 3401 of the Internal Revenue Service Restructuring and Reform Act of 1998. They affect taxpayers against whose property or rights to property the IRS files a NFTL. |
| REG-159079-01(PDF, 18K) |
|
1/17/2002 |
| Taxpayer Identification Number Rule Where Taxpayer Claims Treaty Rate and Is Entitled to an Immediate Payment |
| This document contains proposed regulations that provide additional guidance needed to comply with the withholding rules under section 1441 and conforming changes to the regulations under section 6109. Specifically, these proposed regulations provide rules that facilitate compliance by withholding agents where foreign individuals who are claiming reduced rates of withholding under an income tax treaty receive an unexpected payment from the withholding agent, yet do not possess the required individual taxpayer identification number. The text of the temporary regulations on this subject in this issue of the Federal Register, also serves as the text of these proposed regulations set forth in this cross-referenced notice of proposed rulemaking. |
| T.D. 8977(PDF, 39K) |
|
1/17/2002 |
| Taxpayer Identification Number Rule Where Taxpayer Claims Treaty Rate and Is Entitled to an Unexpected Payment |
| This document contains temporary regulations that provide additional guidance needed to comply with the withholding rules under section 1441 and conforming changes to the regulations under section 6109. Specifically, these temporary regulations provide rules that facilitate compliance by withholding agents where foreign individuals who are claiming reduced rates of withholding under an income tax treaty receive an unexpected payment from the withholding agent, yet do not possess the required individual taxpayer identification number. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the cross-referenced notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. |
| T.D. 8973(PDF, 40K) |
|
1/8/2002 |
| Allocation of Loss with Respect to Stock and Other Personal Property |
| This document contains final Tax Regulations which remove temporary regulations relating to the allocation of loss recognized on the disposition of stock and other personal property. The loss allocation regulations primarily will affect taxpayers that claim the foreign tax credit and that incur losses with respect to personal property and are necessary to modify existing guidance with respect to loss allocation. |
| T.D. 8972(PDF, 37K) |
|
1/8/2002 |
| Averaging of Farm Income |
| This document contains final regulations relating to the election to average farm income in computing tax liability. The regulations reflect changes to the law made by the Taxpayer Relief Act of 1997, as amended by the Tax and Trade Relief Extension Act of 1998, and provide guidance to individuals engaged in a farming business. |
| REG-125450-01(PDF, 27K) |
|
1/5/2002 |
| Liability For Insurance Premium Excise Tax |
| This document contains proposed amendments to the regulations relating to liability for the insurance premium excise tax. This document affects persons who make, sign, issue, or sell a policy of insurance, indemnity bond, annuity contract, or policy of reinsurance issued by any foreign insurer or reinsurer. This document also provides a notice of public hearing on these proposed regulations. |
| T.D. 8975(PDF, 66K) |
|
1/2/2002 |
| Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs] |
| This document contains temporary regulations that apply to certain transactions or events that result in a Regulated Investment Company [RIC] or a Real Estate Investment Trust [REIT] owning property that has a basis determined by reference to a C corporation's basis in the property. These regulations affect RICs, REITs, and C corporations and clarify the tax treatment of transfers of C corporation property to a RIC or REIT. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. |
| REG-142299-01(PDF, 11K) |
|
1/2/2002 |
| Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts |
| This document contains proposed regulations that apply to certain transactions or events that result in a Regulated Investment Company [RIC] or Real Estate Investment Trust [REIT] owning property that has a basis determined by reference to a C corporation's basis in the property. The text of the temporary regulations published in the Rules and Regulations section of this issue of the Federal Register serves as the text of this proposed regulation. |
