2006 Treasury Decisions
"Treasury Decisions" are either temporary or
final Regulations that have been approved by the Department of the Treasury after submission from the IRS. (Proposed regulations are not approved by the Treasury Dept.) Tax
Regulations are the IRS Commissioner's rules, for the application and administration of the Internal Revenue laws.
Regulations are promulgated by publishing in the Federal Register, and are also published in the weekly Internal Revenue Bulletin. Final regulations carry the force
and effect of law. For more information about IRS Regulations, see the Guide to Understanding the Differences Among Official IRS Documents
| Treasury Decisions |
Bulletin |
Date of IRB |
 |
| T.D. 9297(HTML) |
IRB #2006-50(HTML) |
December 11, 2006 |
| Final regulations under section 937(a) of the Code provide a new alternative under the presence test for determining whether an individual is a bona fide resident of American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands, referred to as U.S. possessions or territories. Generally, an individual is a bona fide resident of a territory if the individual satisfies a presence test, a tax home test and a closer connection test. Under this new alternative, an individual would satisfy the presence test if the individual meets an averaging test for the minimum number of days spent in the relevant territory. |
| T.D. 9296(HTML) |
IRB #2006-50(HTML) |
December 11, 2006 |
| Final regulations under section 41 of the Code provide rules for the computation and allocation of the credit for increasing research activities in the case of a controlled group of corporations or a group of trades or businesses under common control. The regulations also provide rules for making and revoking an election to compute the research credit using the alternative incremental research credit rules. |
| T.D. 9295(HTML) |
IRB #2006-49(HTML) |
December 4, 2006 |
| Final and temporary regulations under sections 6011, 6111, and 6112 of the Code amend the rules relating to requests for private letter rulings regarding reportable transactions and remove the tolling provision from the current regulations. These regulations cross-reference REG-103038-05, REG-103039-05, and REG-103043-05 in this Bulletin. |
| T.D. 9294(HTML) |
IRB #2006-48(HTML) |
November 27, 2006 |
| Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recipient, or to make a participant election or consent, with respect to a retirement plan, an employee benefit plan, or an individual retirement plan. |
| T.D. 9293(HTML) |
IRB #2006-48(HTML) |
November 27, 2006 |
| Final, temporary, and proposed regulations under section 199 of the Code concern the amendments made by the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) to section 199, which provides a deduction for income attributable to domestic production activities. A public hearing on the proposed regulations is scheduled for February 5, 2007. |
| T.D. 9292(HTML) |
IRB #2006-47(HTML) |
November 20, 2006 |
| Final regulations under section 704 of the Code provide that allocations of creditable foreign tax expenditures cannot have substantial economic effect, and, therefore, must be allocated in accordance with the partners' interests in the partnership. The regulations provide a safe harbor whereby allocations of creditable foreign tax expenditures will be deemed to be in accordance with the partners' interests in the partnership. To satisfy the safe harbor, allocations of creditable foreign tax expenditures must be in proportion to the distributive shares of income to which the taxes relate. |
| T.D. 9291(HTML) |
IRB #2006-46(HTML) |
November 13, 2006 |
| Final regulations under section 6330 of the Code relate to a taxpayer's right to a hearing before or after levy. The regulations make certain clarifying changes in the way collection due process hearings are conducted and specify the period during which a taxpayer may request an equivalent hearing. |
| T.D. 9290(HTML) |
IRB #2006-46(HTML) |
November 13, 2006 |
| Final regulations under section 6320 of the Code relate to a taxpayer's right to a hearing after the filing of a notice of federal tax lien (NFTL). The regulations make certain clarifying changes in the way collection due process hearings are conducted and specify the period during which a taxpayer may request an equivalent hearing. |
| T.D. 9289(HTML) |
IRB #2006-45(HTML) |
November 6, 2006 |
| Final regulations under section 752 of the Code contain rules for taking into account certain obligations of a business entity that is disregarded as separate from its owner under section 856(i) or section 1361(b)(3), or regulations sections 301.7701-1 through 301.7701-3. The regulations clarify the existing regulations concerning when a partner may be treated as bearing the economic risk of loss for a partnership liability based upon an obligation of a disregarded entity. |
| T.D. 9288(HTML) |
IRB #2006-44(HTML) |
October 30, 2006 |
| Final regulations under 31 USC 9701 implement new user fees for the special enrollment examination for enrolled agents (SEE), the application for enrollment of enrolled agents, and the renewal of such enrollment. The user fee that the IRS currently charges applicants in order to take the SEE is being modified to reflect the change in IRS costs of administering the exam program as a result of the contracting out of the exam. Furthermore, the user fees that the IRS currently charges applicants for the enrollment and renewal of enrollment process are less than the actual cost of overseeing the enrollment process. The regulations establish an $11 per part per applicant user fee for the SEE and separate $125 user fees for the enrollment and renewal of enrollment process. |
| T.D. 9287(HTML) |
IRB #2006-46(HTML) |
November 13, 2006 |
| Final regulations under section 7702 of the Code explain how to determine the attained age of an insured for purposes of testing whether a contract qualifies as a life insurance contract for federal income tax purposes. |
| T.D. 9286(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| Temporary and proposed regulations under section 45G of the Code provide guidance regarding the railroad track maintenance credit determined for qualified railroad track maintenance expenditures paid or incurred by a Class II or Class III railroad and other eligible taxpayers during the taxable year. A public hearing on the proposed regulations is scheduled for January 9, 2007. |
| T.D. 9285(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| Final regulations under section 448 of the Code provide rules relating to the use of a nonaccrual-experience method of accounting by taxpayers using an accrual method of accounting and performing services. The regulations affect qualifying taxpayers that want to adopt, change to, or change a nonaccrualexperience method of accounting under section 448(d)(5). |
| T.D. 9284(HTML) |
IRB #2006-40(HTML) |
October 2, 2006 |
| Final regulations under section 6502 of the Code incorporate changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS's ability to enter into agreements extending the statute of limitations for collection. |
| T.D. 9283(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| Final regulations under sections 168(k) and 1400L(b) of the Code provide guidance regarding the additional first year depreciation deduction for qualified property and 50-percent bonus depreciation property under section 168(k) and for qualified New York Liberty Zone property under section 1400L(b). |
| T.D. 9282(HTML) |
IRB #2006-39(HTML) |
Sept. 25, 2006 |
| Final regulations under sections 162(k) and 404(k) of the Code provide that a payment in redemption of employer securities held by an employee stock ownership plan (ESOP) is not deductible. |
| T.D. 9281(HTML) |
IRB #2006-39(HTML) |
Sept. 25, 2006 |
| Final, temporary, and proposed regulations under sections 882 and 884 of the Code state that foreign corporations engaged in a trade or business within the United States are subject to tax on their income that is treated as effectively connected with the trade or business. Expenses related to that income are allocable and deductible against the effectively connected income to determine the foreign corporation's net U.S. taxable income. Special rules apply to the allocable amount of interest expense allowed in determining the net U.S. taxable income. Additional rules for foreign banking corporations are also applicable. Certain clarifications and conforming updates are also made to the 1996 final regulations under section 1.882-5. |
| T.D. 9280(HTML) |
IRB #2006-38(HTML) |
Sept. 18, 2006 |
| Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. |
| T.D. 9279(HTML) |
IRB #2006-36(HTML) |
Sept. 5, 2006 |
| Final, temporary, and proposed regulations under section 671 of the Code amend regulations section 1.671-5, reporting rules for widely held fixed investment trusts (WHFITs), to clarify and simplify the application of those rules to non-mortgage widely held fixed investment trusts (NMWHFITs). The proposed regulations also include a requirement that trustees of WHFITs file an information return with the IRS and provide for the IRS to create a directory of NMWHFITs and trustees of widely held mortgage trusts (WHMTs). The proposed regulations clarify the market discount reporting rules under the NMWHFIT safe harbor and solicit comments on the WHMT safe harbor. |
| T.D. 9278(HTML) |
IRB #2006-34(HTML) |
August 21, 2006 |
| Final, temporary, and proposed regulations deal with transfer prices in particular categories of transactions between related parties within the meaning of section 482 of the Code. They provide guidance regarding services transactions by updating regulations under section 482 issued in 1968. The regulations address determination of ownership of intangible property among related parties under section 482 and allocations with respect to "contributions" to the value of intangible property by a related party other than the owner. They also modify the treatment of stewardship expenses under regulations section 1.861-8. The temporary regulations are effective for tax years beginning after December 31, 2006. |
| T.D. 9277(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| Final regulations under section 4980G of the Code provide guidance regarding employer comparable contributions to Health Savings Accounts (HSAs). The regulations provide that if an employer makes comparable contributions to any employee's HSA, the employer must make comparable contributions for the calendar year to the HSAs of all comparable participating employees. In addition, the final regulations set forth the rules for calculating comparable contributions. |
| T.D. 9276(HTML) |
IRB #2006-37(HTML) |
Sept. 11, 2006 |
| Final regulations under section 3402 of the Code concern the definition of supplemental wages for income tax withholding purposes and income tax withholding requirements for employers making payments of supplemental wages to employees. |
| T.D. 9275(HTML) |
IRB #2006-35(HTML) |
August 28, 2006 |
| Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to amend section 1.410(b)-6(g) of the regulations. The final regulations permit, in certain circumstances, employees of a tax-exempt organization described in section 501(c)(3) to be excluded for the purpose of testing whether a section 401(k) plan (or a section 401(m) plan that is provided under the same general arrangement as the section 401(k) plan of the employer) meets the requirements for minimum coverage specified in section 410(b). The regulations affect tax-exempt employers described in section 501(c)(3), retirement plans sponsored by these employers, and participants in these plans. (Continued on the next page) |
| T.D. 9274(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| Final regulations under section 6103 of the Code describe the circumstances under which IRS and the Office of Treasury Inspector General for Tax Administration (TIGTA) employees may disclose return information for investigative purposes. The regulations clarify and elaborate on the types of situations and contexts in which investigative disclosures may be made. |
| T.D. 9273(HTML) |
IRB #2006-37(HTML) |
Sept. 11, 2006 |
| Final regulations under section 367 of the Code provide guidance with respect to the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a foreign-to-foreign or inbound corporate reorganization or liquidation described in both section 367(b) and section 381. |
| T.D. 9272(HTML) |
IRB #2006-35(HTML) |
August 28, 2006 |
| Final, temporary, and proposed regulations under section 860G of the Code relate to income that is associated with a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) and that is allocated through certain entities to foreign persons who have invested in those entities. The regulations accelerate the time when income is recognized for withholding tax purposes to conform to the timing of income recognition for general income tax purposes. |
| T.D. 9271(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| Final regulations under section 338 of the Code provide that the step transaction doctrine will not be applied if a taxpayer makes a valid section 338(h)(10) election with respect to a step in a multi-step transaction, even if the transaction would otherwise qualify as a reorganization if the step standing alone is a qualified stock purchase. |
| T.D. 9270(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| Final regulations under section 6045(f) of the Code relate to information reporting for payments of gross proceeds to attorneys. Regulations under section 6041 are also amended with respect to information reporting for payments for legal services. |
| T.D. 9269(HTML) |
IRB #2006-30(HTML) |
July 24, 2006 |
| Final regulations under section 382 of the Code provide guidance on whether a loss corporation has an owner shift where a qualified trust described in section 401(a) distributes an ownership interest in an entity. |
| T.D. 9268(HTML) |
IRB #2006-30(HTML) |
July 24, 2006 |
| Final, temporary, and proposed regulations provide guidance under sections 6038 and 6038A of the Code. The final regulations under section 1.6038-2 are revised to remove and replace obsolete references to a form and IRS offices. The regulations clarify the information required to be furnished regarding certain related party transactions of certain foreign corporations and certain foreign-owned domestic corporations. The regulations also increase the amount of certain penalties, and make certain other changes, to reflect the statutory changes made by the Taxpayer Relief Act of 1997. |
| T.D. 9267(HTML) |
IRB #2006-34(HTML) |
August 21, 2006 |
| Temporary and proposed regulations under section 6103 of the Code provide additional items of return information disclosable to the Bureau of Economic Analysis of the Department of Commerce. |
| T.D. 9266(HTML) |
IRB #2006-28(HTML) |
July 10, 2006 |
| Final regulations under sections 3102 and 3121 of the Code contain amendments to the employment tax regulations. The regulations provide guidance concerning the application of the Federal Insurance Contributions Act (FICA) to cash payments made for service not in the course of the employer's trade or business, for domestic service in a private home of the employer, for agricultural labor, and for service performed as a home worker within the meaning of section 3121(d)(3)(C). |
| T.D. 9265(HTML) |
IRB #2006-27(HTML) |
July 3, 2006 |
| Temporary and proposed regulations under section 7874(a)(2)(B) of the Code provide rules for determining whether a foreign corporation is a surrogate foreign corporation. Specifically, the regulations explain when there is an indirect acquisition of a domestic corporation's properties for purposes of section 7874(a)(2)(B). The regulations provide guidance for determining when the expanded affiliated group has substantial business activities in a foreign country for purposes of section 7874(a)(2)(B)(iii). In addition, the regulations include a rule that in certain situations, a publicly traded partnership may be treated as a surrogate foreign corporation. The regulations also provide rules for the treatment of options of the surrogate foreign corporation for purposes of section 7874(a)(2)(B)(ii). A public hearing on the proposed regulations is scheduled for October 24, 2006. |
| T.D. 9264(HTML) |
IRB #2006-26(HTML) |
June 26, 2006 |
| Final, temporary, and proposed regulations under section 1502 of the Code and others simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns. |
| T.D. 9263(HTML) |
IRB #2006-25(HTML) |
June 19, 2006 |
| Final regulations under section 199 of the Code relate to the deduction for income attributable to domestic production activities. Section 199 was enacted as part of the American Jobs Creation Act (AJCA) of 2004, and allows a deduction equal to 3 percent (for 2005 and 2006) of the lesser of the qualified production activities income of the taxpayer for the taxable year, or the taxable income of the taxpayer for the taxable year, subject to certain limits. The applicable percentage rises to 6 percent for 2007, 2008, and 2009, and 9 percent for 2010 and subsequent years. Notice 2005-14 obsoleted for taxable years beginning on or after June 1, 2006. |
| T.D. 9262(HTML) |
IRB #2006-24(HTML) |
June 12, 2006 |
| Temporary and proposed regulations concern the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities, to certain transactions involving computer software. A public hearing on the proposed regulations is scheduled for August 29, 2006. |
| T.D. 9261(HTML) |
IRB #2006-21(HTML) |
May 22, 2006 |
| Final regulations under section 1502 of the Code relate to intercompany transactions. Section 1.1502-13(c)(7)(ii), Example 13, illustrates the treatment of manufacturer incentive payments. This example relies, in part, upon the premise that manufacturer incentive payment is an ordinary and necessary business expense deductible under section 162. Because this treatment is now under reconsideration (see Rev. Rul. 2005-28, 2005-19 I.R.B. 997), these final regulations remove and reserve this example. |
| T.D. 9260(HTML) |
IRB #2006-23(HTML) |
June 5, 2006 |
| Temporary and proposed regulations under section 904 of the Code provide guidance relating to the look-through treatment of dividends from noncontrolled section 902 corporations (10/50 corporations). The American Jobs Creation Act (AJCA) of 2004 amended section 904(d) and repealed the separate limitation category for dividends from 10/50 corporations effective for taxable years beginning after December 31, 2002. The temporary regulations also provide guidance concerning the Gulf Opportunity Zone Act of 2005, which permitted taxpayers to elect to defer the effective date of the AJCA amendments until after taxable years beginning after December 31, 2004. |
| T.D. 9259(HTML) |
IRB #2006-19(HTML) |
May 8, 2006 |
| Final regulations under section 368 of the Code amend final regulations (T.D. 9242, 2006-7 I.R.B. 422) concerning statutory mergers and consolidations under section 368(a)(1)(A). This amendment provides transitional relief for certain transactions initiated before January 23, 2006. Taxpayers can elect to apply the earlier temporary regulations (T.D. 9038, 2003-1 C.B. 524). |
| T.D. 9258(HTML) |
IRB #2006-20(HTML) |
May 15, 2006 |
| Temporary and proposed regulations under section 1502 of the Code revise the tacking rule of the life-nonlife consolidated regulations by eliminating the requirement relating to the separation of profitable and loss activities. |
| T.D. 9257(HTML) |
IRB #2006-17(HTML) |
April 24, 2006 |
| Final regulations under section 338 of the Code apply to a deemed sale or acquisition of an insurance company's assets, to a sale or acquisition of an insurance trade or business, and to the acquisition of insurance contracts through assumption reinsurance. It also contains final regulations concerning the effect of certain corporate liquidations and reorganizations on certain tax attributes of insurance companies. This document also contains temporary and proposed regulations relating to the determination of adjusted basis of amortizable section 197 intangibles, increases in reserves after a deemed asset sale, and the carryover of an election to use a company's historical loss payment pattern. |
| T.D. 9256(HTML) |
IRB #2006-16(HTML) |
April 17, 2006 |
| Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable under certain retirement plans. |
| T.D. 9255(HTML) |
IRB #2006-15(HTML) |
April 10, 2006 |
| Final, temporary, and proposed regulations under section 1502 of the Code provide the IRS with the authority to designate a domestic member of a consolidated group as a substitute agent to act as the sole agent for the group where the common parent is a foreign entity that is treated as a domestic corporation pursuant to section 7874(b) or as the result of a section 953(d) election. |
| T.D. 9254(HTML) |
IRB #2006-13(HTML) |
March 27, 2006 |
| Final regulations under section 1502 of the Code apply when a member of a consolidated group sells subsidiary stock at a loss. They also apply when a member holds loss shares of subsidiary stock and the subsidiary ceases to be a member of the group. The regulations generally limit duplicated losses by redetermining stock basis, suspending stock loss, or adjusting inside loss. These regulations finalize section 1.1502-35T without substantive change. |
| T.D. 9253(HTML) |
IRB #2006-14(HTML) |
April 3, 2006 |
| The Treasury Department and the IRS issued comprehensive withholding and reporting regulations (T.D. 8734 and T.D. 8881) that became effective on January 1, 2001. In Notice 2001-4, 2001-1 C.B. 267; Notice 2001-11, 2001-1 C.B. 464; and Notice 2001-43, 2001-2 C.B. 72; the Treasury Department and the IRS announced the intention to amend the final regulations. These final regulations implement certain changes announced in those notices and other changes. In addition, these final regulations provide guidance under section 411 of the American Jobs Act of 2004. Notice 2001-11 and certain sections of Notices 2001-4 and 2001-43 superseded. |
| T.D. 9252(HTML) |
IRB #2006-12(HTML) |
March 20, 2006 |
| Temporary and proposed regulations under section 6103 of the code are provided regarding administrative review procedures for certain government agencies and other authorized recipients of tax returns or return information (authorized recipients) whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards. The regulations provide guidance to responsible irs personnel and authorized recipients as to these administrative procedures. |
| T.D. 9251(HTML) |
IRB #2006-11 (HTML) |
March 13, 2006 |
| Final regulations under section 951(a) of the Code provide special rules to ensure that earnings and profits of a controlled foreign corporation attributable to a section 304 transaction will not be allocated in a manner that results in the avoidance of income tax and to ensure that earnings and profits of a controlled foreign corporation are not allocated to certain preferred stock in a manner inconsistent with the economic interest that such stock represents. |
| T.D. 9250(HTML) |
IRB #2006-11 (HTML) |
March 13, 2006 |
| Final regulations under sections 367(a) and (b) of the Code concern transfers pursuant to section 304(a)(1). Rev. Ruls. 91-5 and 92-86 modified. |
| T.D. 9249(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| Final regulations under section 468B of the Code provide rules for the taxation and reporting of income earned on qualified settlement funds, escrow accounts established in connection with sales of property, and disputed ownership funds. Rev. Rul. 77-230 obsoleted. |
| T.D. 9248(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| Final and temporary regulations under section 937 of the Code provide rules for determining whether an individual is a bona fide resident of American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands. The regulations also provide rules for determining residency for purposes of section 881(b). Related regulations concerning the source and effectively connected income rules, together with other conforming changes, particularly under sections 931 through 935, will be finalized in a forthcoming Treasury decision. |
| T.D. 9247(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| Final and temporary regulations under section 861 of the Code provide an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of regulations section 1.861-9T. |
| T.D. 9246(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| Some business entities may be recognized under state or foreign law as created or organized in more than one jurisdiction at the same time (“dually chartered entities”). Final regulations under section 7701 of the Code provide clarification regarding how to determine the federal tax classification (e.g., corporation, partnership, or an entity disregarded as separate from its owner) of a dually chartered entity and how to determine whether a dually chartered entity is domestic or foreign. |
| T.D. 9245(HTML) |
IRB #2006-14(HTML) |
April 3, 2006 |
| Final regulations under section 6103(j) of the Code incorporate and clarify the phrase "return information reflected on returns" in conformance with the terms of section 6103(j)(5), which provides for limited disclosures of returns and return information in connection with the census of agriculture. |
| T.D. 9244(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| Final regulations under section 358 of the Code provide a tracing approach for the determination of basis of stock or securities received in exchange for or with respect to stock and securities in certain transactions. Temporary and proposed regulations under section 1502 of the Code provide additional guidance on the treatment of an excess loss account when a consolidated group member’s original shares have an excess loss account or the member would otherwise determine that new shares would have an excess loss account at the time of a basis adjustment or determination under the Internal Revenue Code. Rev. Rul. 55-355 obsoleted. |
| T.D. 9243(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| Final and temporary regulations under section 367 of the Code amend income tax regulations under sections 367, 884, and 6038B dealing with statutory mergers or consolidations under section 368(a)(1)(A) involving one or more foreign corporations, and provide guidance necessary to facilitate business electronic filing under section 6038B. |
| T.D. 9242(HTML) |
IRB #2006-07(HTML) |
February 13, 2006 |
| Final regulations under section 368 of the Code define the term statutory merger or consolidation as used in the Internal Revenue Code. The regulations remove the requirement in temporary regulations that transactions must be carried out under domestic law in order to qualify as a statutory merger or consolidation. The regulations also provide that a transaction may qualify even if it involves foreign entities. They also provide a special rule that addresses the qualification as a statutory merger or consolidation of a transaction involving certain entities that are disregarded as entities separate from their corporate owners for federal income tax purposes. |
| T.D. 9241(HTML) |
IRB #2006-07(HTML) |
February 13, 2006 |
| Final regulations under section 671 of the Code define widely held fixed investment trusts, clarify the reporting obligations of the trustees and the middlemen connected with these trusts, and provide for communication of tax information to beneficial owners of trust interests. |
| T.D. 9240(HTML) |
IRB #2006-07(HTML) |
February 13, 2006 |
| Final, temporary, and proposed regulations under section 954 of the Code contain rules for determining whether a controlled foreign corporation’s (CFC’s) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception). These regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs. |
| T.D. 9239(HTML) |
IRB #2006-06(HTML) |
February 6, 2006 |
| Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance Contributions Act (FICA) and returns of income tax withheld. The regulations require employers who receive notification of qualification for the Employers’ Annual Federal Tax Program (Form 944) to file Form 944, Employer’s Annual Federal Tax Return, annually instead of Form 941, Employer’s Quarterly Federal Tax Return, quarterly beginning in the 2006 taxable year. The regulations also permit most employers who file Form 944 to remit accumulated employment taxes annually with their return and modify the lookback period and de minimis deposit rule for these employers. The proposed regulations also provide an additional method for quarterly return filers to determine whether the amount of accumulated employment taxes is considered de minimis. A public hearing on the proposed regulations is scheduled for April 26, 2006. |
| T.D. 9238(HTML) |
IRB #2006-06(HTML) |
February 6, 2006 |
| Temporary and proposed regulations under section 7874 of the Code provide for determination of whether a foreign corporation is a surrogate foreign corporation when the foreign corporation is part of an expanded affiliated group. A public hearing on the proposed regulations is scheduled for April 27, 2006. |
| T.D. 9237(HTML) |
IRB #2006-06(HTML) |
February 6, 2006 |
| Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements. |
| T.D. 9236(HTML) |
IRB #2006-05(HTML) |
January 30, 2006 |
| Final regulations under section 1374 of the Code provide that (a) section 1374(d)(8) applies to any transaction described in that section that occurs on or after December 27, 1994, regardless of the date of the S corporation’s election under section 1362; and (b) for purposes of section 633(d)(8) of the Tax Reform Act of 1986, as amended, a corporation’s most recent S election, not an earlier election that has been revoked or terminated, determines whether or not it is subject to current section 1374. |
| T.D. 9235(HTML) |
IRB #2006-04(HTML) |
January 23, 2006 |
| Final and temporary regulations under section 7701 of the Code make additions to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. |
| T.D. 9234(HTML) |
IRB #2006-04(HTML) |
January 23, 2006 |
| Final regulations under section 141 of the Code provide rules in regulations section 1.141-13 for the application of the private activity bond tests to bonds issued to refund prior bonds. Section 1.141-13 was previously reserved when the comprehensive private activity bonds were released in 1997. The regulations will generally be effective on the date they are published in the Federal Register. |
| T.D. 9233(HTML) |
IRB #2006-03(HTML) |
January 17, 2006 |
| Final regulations under section 3121 of the Code provide guidance for payments made on account of sickness or accident disability under a workers’ compensation law for purposes of the Federal Insurance Contributions Act (FICA). |
| T.D. 9232(HTML) |
IRB #2006-02(HTML) |
January 9, 2006 |
| Temporary and proposed regulations under section 1297 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC. A public hearing on the proposed regulations is scheduled for March 22, 2006. |
| T.D. 9231(HTML) |
IRB #2006-02(HTML) |
January 9, 2006 |
| Final regulations under section 1298 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC. |
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