INCOME TAX

Rev. Rul. 2005-54(HTML)
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2005.

T.D. 9210(HTML)
Final regulations under section 1363(d) of the Code address LIFO recapture by corporations converting from C corporations to S corporations. The purpose of these regulations is to provide guidance on the LIFO recapture requirement when the corporation holds inventory accounted for under the last-in, first-out (LIFO) method (LIFO inventory) indirectly through a partnership.

T.D. 9211(HTML)
Final regulations under section 861 of the Code provide that deductions for charitable contributions (as defined in section 170(c)) are definitely related and allocable to all of a taxpayer’s gross income and are apportioned on the basis of income from sources within the United States. In addition, regulations are finalized in this document with respect to the allocation and apportionment of deductions for charitable contributions that are provided by an income tax treaty rather than by sections 170, 873(b)(2), and 882(c)(1)(B).

Rev. Proc. 2005-51(HTML)
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).

Rev. Rul. 2005-55(HTML)
Profit-sharing plan; retiree health accounts; nonforfeitability; prospective application. This ruling holds that a sub-account within a profit-sharing plan that provides medical reimbursement expenses to each participant does not meet the provisions of section 411 of the Code on nonforfeitability because it imposes conditions on the use of the amounts held in the participants’ accounts. If certain criteria are met, the ruling will be applied prospectively.

REG-138362-04(HTML)
Proposed regulations under section 401 of the Code provide guidance on the use of electronic media to provide certain notices to recipients or to transmit participant and beneficiary elections or consents with respect to employee benefit arrangements. A public hearing is scheduled for November 2, 2005.

Notice 2005-58(HTML)
This notice addresses certain income tax issues with respect to nonqualified deferred compensation plans maintained by federal credit unions, including whether a federal credit union can maintain an eligible nonqualified deferred compensation plan described in section 457 of the Code, and issues relating to plans in effect on publication of this notice that are intended to satisfy section 457.

Notice 2005-58(HTML)
This notice addresses certain income tax issues with respect to nonqualified deferred compensation plans maintained by federal credit unions, including whether a federal credit union can maintain an eligible nonqualified deferred compensation plan described in section 457 of the Code, and issues relating to plans in effect on publication of this notice that are intended to satisfy section 457.

Announcement 2005-58(HTML)
A list is provided of organizations now classified as private foundations.

Rev. Proc. 2005-51(HTML)
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).

Announcement 2005-55(HTML)
This document withdraws proposed regulations (REG-142686-01, 2001-2 C.B. 561) concerning the application of FICA, FUTA, and federal income tax withholding to stock options issued under an employee stock purchase plan or an incentive stock option plan (collectively, statutory stock options).

EXCISE TAX

Rev. Proc. 2005-51(HTML)
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).

Rev. Proc. 2005-51(HTML)
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).

Announcement 2005-56(HTML)
This document contains corrections to proposed regulations (REG-102144-04, 2005-25 I.R.B. 1297) relating to dual consolidated loss issues.

Announcement 2005-57(HTML)
This document contains corrections to proposed regulations (REG-100420-03, 2005-24 I.R.B. 1236) relating to elective safe harbor for dealers and traders in securities and commodities.