Internal Revenue Bulletins  
September 6, 2005

Internal Revenue Bulletin No. 2005-36

Official IRS Bulletin Documents linked below are in HTML: Revenue Rulings, Revenue Procedures, Announcements, Notices, Treasury Decisions, Regulations, Treaties, etc.
Definition of Terms Used by the IRS in Official Documents
Guide to Understanding the Differences Among Official IRS Documents

INCOME TAX

Rev. Rul. 2005-57(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 September 2005.

Rev. Rul. 2005-58(HTML)
Mutual life insurance companies; differential earnings rate. The differential earnings rate for 2004 is determined for use by mutual life insurance companies to compute their income tax liability for 2004.

T.D. 9216(HTML)
Final regulations under section 269B of the Code concern the definition and treatment of a stapled foreign corporation, which is generally treated for U.S. tax purposes as a domestic corporation. The regulations also put in regulation form Notices 89-94 and 2003-50, treating a stapled foreign corporation as foreign for purposes of determining whether it is an includible corporation within the meaning of section 1504(d), except when applying sections 1.904(i)-1 and 1.861-11T(d)(6) of the regulations.

Notice 2005-64(HTML)
This is the third in a series of notices, including Notice 2005-10, 2005-6 I.R.B. 474, and Notice 2005-38, 2005-22 I.R.B. 1100, providing guidance on the one time dividends received deduction (DRD) under section 965 for certain cash dividends from controlled foreign corporations that are invested in the United States. This notice provides guidance with respect to the foreign tax credit and related issues under section 965, foreign currency translation, the alternative minimum tax, and the credit for prior year minimum tax. Notice 2005-10 clarified and Notice 2005-38 modified.

Rev. Proc. 2005-63(HTML)
Time periods for requesting consent to change a method of accounting. For a taxpayer desiring consent to change a method of accounting provided for under certain regulations, this procedure waives the requirement to request consent within the time periods prescribed in those regulations provided the taxpayer requests consent in accordance with this procedure. Rev. Proc. 83-77 superseded.

Rev. Proc. 2005-64(HTML)
This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2003.

ADMINISTRATIVE

T.D. 9215(HTML)
REG-131739-03(HTML)
Temporary and proposed regulations under section 6020 of the Code modify the provisions of the current regulations section 301.6020-1 to provide the following: (1) a document (or set of documents) signed by the Commissioner or other authorized Internal Revenue officer or employee shall be a return under section 6020(b) if the document (or set of documents) identifies the taxpayer by name and taxpayer identification number, contains sufficient information from which to compute the taxpayer’s tax liability, and the document (or set of documents) purports to be a return; (2) the document and subscription may be in written or electronic form; and (3) pursuant to section 6651(g)(2), the document that constitutes a return under section 6020(b) will be treated as the return filed by the taxpayer for purposes of determining the amount of the addition to tax under sections 6651(a)(2) and (a)(3).

Rev. Proc. 2005-64(HTML)
This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2003.

Announcement 2005-61(HTML)
This document contains a correction to Announcement 2005-53, 2005-31 I.R.B. 258, which corrected T.D. 9186 relating to qualified amended returns.

Announcement 2005-62(HTML)
This document contains corrections to T.D. 9193, 2005-15 I.R.B. 862, by adding the text that was inadvertently omitted from the Code of Federal Regulations. The regulations relate to the tax treatment of installment obligations and property acquired pursuant to a contract.

Announcement 2005-63(HTML)
This document contains corrections to temporary regulations (T.D. 9205, 2005-25 I.R.B. 1267) relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control.

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