26 CFR 1.707-1 - Transactions between partner and partnership.

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§ 1.707-1

Transactions between partner and partnership.

(a) Partner not acting in capacity as partner. A partner who engages in a transaction with a partnership other than in his capacity as a partner shall be treated as if he were not a member of the partnership with respect to such transaction. Such transactions include, for example, loans of money or property by the partnership to the partner or by the partner to the partnership, the sale of property by the partner to the partnership, the purchase of property by the partner from the partnership, and the rendering of services by the partnership to the partner or by the partner to the partnership. Where a partner retains the ownership of property but allows the partnership to use such separately owned property for partnership purposes (for example, to obtain credit or to secure firm creditors by guaranty, pledge, or other agreement) the transaction is treated as one between a partnership and a partner not acting in his capacity as a partner. However, transfers of money or property by a partner to a partnership as contributions, or transfers of money or property by a partnership to a partner as distributions, are not transactions included within the provisions of this section. In all cases, the substance of the transaction will govern rather than its form. See paragraph (c)(3) of § 1.731-1.

(b) Certain sales or exchanges of property with respect to controlled partnerships— (1) Losses disallowed. No deduction shall be allowed for a loss on a sale or exchange of property (other than an interest in the partnership, directly or indirectly, between a partnership and a partner who owns, directly or indirectly, more than 50 percent of the capital interest or profits interest in such partnership. A loss on a sale or exchange of property, directly or indirectly, between two partnerships in which the same persons own, directly or indirectly, more than 50 percent of the capital interest or profits interest in each partnership shall not be allowed.

(ii) If a gain is realized upon the subsequent sale or exchange by a transferee of property with respect to which a loss was disallowed under the provisions of subdivision (i) of this subparagraph, section 267(d) (relating to amount of gain where loss previously disallowed) shall apply as though the loss were disallowed under section 267(a)(1).

(2) Gains treated as ordinary income. Any gain recognized upon the sale or exchange, directly or indirectly, of property which, in the hands of the transferee immediately after the transfer, is property other than a capital asset, as defined in section 1221, shall be ordinary income if the transaction is between a partnership and a partner who owns, directly or indirectly, more than 80 percent of the capital interest or profits interest in the partnership. This rule also applies where such a transaction is between partnerships in which the same persons own, directly or indirectly, more than 80 percent of the capital interest or profits interest in each partnership. The term property other than a capital asset includes (but is not limited to) trade accounts receivable, inventory, stock in trade, and depreciable or real property used in the trade or business.

(3) Ownership of a capital or profits interest. In determining the extent of the ownership by a partner, as defined in section 761(b), of his capital interest or profits interest in a partnership, the rules for constructive ownership of stock provided in section 267(c) (1), (2), (4), and (5) shall be applied for the purpose of section 707(b) and this paragraph. Under these rules, ownership of a capital or profits interest in a partnership may be attributed to a person who is not a partner as defined in section 761(b) in order that another partner may be considered the constructive owner of such interest under section 267(c). However, section 707(b)(1)(A) does not apply to a constructive owner of a partnership interest since he is not a partner as defined in section 761(b). For example, where trust T is a partner in the partnership ABT, and AW, A's wife, is the sole beneficiary of the trust, the ownership of a capital and profits interest in the partnership by T will be attributed to AW only for the purpose of further attributing the ownership of such interest to A. See section 267(c) (1) and (5). If A, B, and T are equal partners, then A will be considered as owning more than 50 percent of the capital and profits interest in the partnership, and losses on transactions between him and the partnership will be disallowed by section 707(b)(1)(A). However, a loss sustained by AW on a sale or exchange of property with the partnership would not be disallowed by section 707, but will be disallowed to the extent provided in paragraph (b) of § 1.267(b)-1. See section 267 (a) and (b), and the regulations thereunder.

(c) Guaranteed payments. Payments made by a partnership to a partner for services or for the use of capital are considered as made to a person who is not a partner, to the extent such payments are determined without regard to the income of the partnership. However, a partner must include such payments as ordinary income for his taxable year within or with which ends the partnership taxable year in which the partnership deducted such payments as paid or accrued under its method of accounting. See section 706(a) and paragraph (a) of § 1.706-1. Guaranteed payments are considered as made to one who is not a member of the partnership only for the purposes of section 61(a) (relating to gross income) and section 162(a) (relating to trade or business expenses). For a guaranteed payment to be a partnership deduction, it must meet the same tests under section 162(a) as it would if the payment had been made to a person who is not a member of the partnership, and the rules of section 263 (relating to capital expenditures) must be taken into account. This rule does not affect the deductibility to the partnership of a payment described in section 736(a)(2) to a retiring partner or to a deceased partner's successor in interest. Guaranteed payments do not constitute an interest in partnership profits for purposes of sections 706(b)(3), 707(b), and 708(b). For the purposes of other provisions of the internal revenue laws, guaranteed payments are regarded as a partner's distributive share of ordinary income. Thus, a partner who receives guaranteed payments for a period during which he is absent from work because of personal injuries or sickness is not entitled to exclude such payments from his gross income under section 105(d). Similarly, a partner who receives guaranteed payments is not regarded as an employee of the partnership for the purposes of withholding of tax at source, deferred compensation plans, etc. The provisions of this paragraph may be illustrated by the following examples:

Example 1. Under the ABC partnership agreement, partner A is entitled to a fixed annual payment of $10,000 for services, without regard to the income of the partnership. His distributive share is 10 percent. After deducting the guaranteed payment, the partnership has $50,000 ordinary income. A must include $15,000 as ordinary income for his taxable year within or with which the partnership taxable year ends ($10,000 guaranteed payment plus $5,000 distributive share).

Example 2. Partner C in the CD partnership is to receive 30 percent of partnership income as determined before taking into account any guaranteed payments, but not less than $10,000. The income of the partnership is $60,000, and C is entitled to $18,000 (30 percent of $60,000) as his distributive share. No part of this amount is a guaranteed payment. However, if the partnership had income of $20,000 instead of $60,000, $6,000 (30 percent of $20,000) would be partner C's distributive share, and the remaining $4,000 payable to C would be a guaranteed payment.

Code of Federal Regulations - Page 556

Example 3. Partner X in the XY partnership is to receive a payment of $10,000 for services, plus 30 percent of the taxable income or loss of the partnership. After deducting the payment of $10,000 to partner X, the XY partnership has a loss of $9,000. Of this amount, $2,700 (30 percent of the loss) is X's distributive share of partnership loss and, subject to section 704(d), is to be taken into account by him in his return. In addition, he must report as ordinary income the guaranteed payment of $10,000 made to him by the partnership.

Example 4. Assume the same facts as in example 3 of this paragraph, except that, instead of a $9,000 loss, the partnership has $30,000 in capital gains and no other items of income or deduction except the $10,000 paid X as a guaranteed payment. Since the items of partnership income or loss must be segregated under section 702(a), the partnership has a $10,000 ordinary loss and $30,000 in capital gains. X's 30 percent distributive shares of these amounts are $3,000 ordinary loss and $9,000 capital gain. In addition, X has received a $10,000 guaranteed payment which is ordinary income to him.

[T.D. 6500, 25 FR 11814, Nov. 26, 1960, as amended by T.D. 7891, 48 FR 20049, May 4, 1983]

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2012-03-28; vol. 77 # 60 - Wednesday, March 28, 2012

77 FR 18686 - Apportionment of Tax Items Among the Members of a Controlled Group of Corporations

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DEPARTMENT OF THE TREASURY, Internal Revenue Service

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Summary

77 FR 18687 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Correction

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DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations; correcting amendment.

Effective Date: March 28, 2012.

26 CFR Part 1

Summary

This document contains correcting amendments to temporary regulations (TD 9564), which were published in the Federal Register relating to guidance regarding deduction and capitalization of expenditures related to tangible property.

2012-03-08; vol. 77 # 46 - Thursday, March 8, 2012

77 FR 13968 - Dividend Equivalents From Sources Within the United States; Correction

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FR Doc.	2012-5315
RIN	1545-BK53
TD	9572

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations; correcting amendment.

Effective Date: March 8, 2012 and is applicable January 23, 2012.

26 CFR Part 1

Summary

This document contains corrections to temporary regulations (TD 9572), relating to dividend equivalents from sources within the United States.

2012-02-21; vol. 77 # 34 - Tuesday, February 21, 2012

77 FR 9844 - Allocation and Apportionment of Interest Expense; Correction

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FR Doc.	2012-3855
RIN	1545-BJ84
TD	9571

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on February 21, 2012, and is applicable on January 17, 2012.

26 CFR Part 1

Summary

This document contains corrections to the final regulations (TD 9571), which were published in the Federal Register on January 17, 2012 (77 FR 2225) that provide guidance regarding the allocation and apportionment of interest expense.

77 FR 9845 - Reporting of Specified Foreign Financial Assets; Correction

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FR Doc.	2012-3935
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

Effective date: This correction is effective February 21, 2012, and is applicable beginning December 19, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations (TD 9567), which were published in the Federal Register on Monday, December 19, 2011, relating to the reporting of specified foreign financial assets.

77 FR 9845 - Reporting of Specified Foreign Financial Assets; Correction

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FR Doc.	2012-3936
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final rule; correction.

Effective Date: This correction is effective February 21, 2012, and is applicable beginning December 19, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations (TD 9567), which were published in the Federal Register on Monday, December 19, 2011, relating to reporting of specified foreign financial assets.

77 FR 9846 - Source of Income From Qualified Fails Charges

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FR Doc.	2012-3909
RIN	1545-BJ78
TD	9579

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date. These regulations are effective on February 21, 2012. Applicability Date. For the date of applicability, see § 1.863-10(g).

26 CFR Part 1

Summary

This document contains final regulations that prescribe the source of income received on a qualified fails charge under section 863 of the Internal Revenue Code (Code). The regulations finalize proposed regulations and withdraw temporary regulations published on December 8, 2010, and affect persons that pay or are entitled to receive qualified fails charges, including withholding agents.

2012-02-14; vol. 77 # 30 - Tuesday, February 14, 2012

77 FR 8120 - Definition of a Taxpayer

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FR Doc.	2012-3352
RIN	1545-BF73
TD	9576

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on February 14, 2012. Applicability Dates: For dates of applicability, see § 1.901-2(h)(4).

26 CFR Part 1

Summary

This document contains final Income Tax Regulations which provide guidance relating to the determination of who is considered to pay a foreign income tax for purposes of the foreign tax credit. These regulations provide rules for identifying the person with legal liability to pay the foreign income tax in certain circumstances. These regulations affect taxpayers claiming foreign tax credits.

77 FR 8127 - Foreign Tax Credit Splitting Events

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FR Doc.	2012-3356
RIN	1545-BK50
TD	9577

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on February 14, 2012. Applicability Dates: For dates of applicability, see §§ 1.704-1T(b)(1)(ii)( b )( 3 ), 1.909-1T(e), 1.909-2T(c), 1.909-3T(c), 1.909-4T(b), 1.909-5T(c), and 1.909-6T(h).

26 CFR Part 1

Summary

This document contains final and temporary Income Tax Regulations with respect to a new provision of the Internal Revenue Code (Code) that addresses situations in which foreign income taxes have been separated from the related income. These regulations are necessary to provide guidance on applying the new statutory provision, which was enacted as part of legislation commonly referred to as the Education Jobs and Medicaid Assistance Act (EJMAA) on August 10, 2010. These regulations affect taxpayers claiming foreign tax credits. The text of the temporary regulations also serves as the text of the proposed regulations (REG-132736-11) published in the Proposed Rules section of this issue of the Federal Register .

77 FR 8143 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

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FR Doc.	2012-3351
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on February 14, 2012 and is applicable beginning December 22, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations (TD 9568), which were published in the Federal Register on Thursday, December 22, 2011 (76 FR 80082), relating to section 482 and methods to determine taxable income in connection with a cost sharing arrangement.

77 FR 8143 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

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FR Doc.	2012-3353
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of correcting amendments.

This correction is effective on February 14, 2012, and is applicable beginnning December 22, 2011.

26 CFR Part 1

Summary

This document contains corrections to a correcting amendment (TD 9568), which was published in the Federal Register on Wednesday, January 25, 2012 (77 FR 3606) relating to section 482 and methods to determine taxable income in connection with a cost sharing arrangement.

2012-02-07; vol. 77 # 25 - Tuesday, February 7, 2012

77 FR 6005 - Application for Recognition as a 501(c)(29) Organization

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RIN	1545-BK64
TD	9574

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on February 7, 2012. Applicability Date: For date of applicability, see § 1.501(c)(29)-1T(c).

26 CFR Part 1

Summary

This document contains temporary regulations authorizing the IRS to prescribe the procedures by which certain entities may apply to the IRS for recognition of exemption from Federal income tax. These regulations affect qualified nonprofit health insurance issuers, participating in the Consumer Operated and Oriented Plan program established by the Centers for Medicare and Medicaid Services, that seek exemption from Federal income tax under the Internal Revenue Code. 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 .

2012-02-06; vol. 77 # 24 - Monday, February 6, 2012

77 FR - Dividend Equivalents From Sources Within the United States

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DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

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2012-01-25; vol. 77 # 16 - Wednesday, January 25, 2012

77 FR 3605 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

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TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final rule; correction.

Effective January 25, 2012, and applicable beginning December 22, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations (TD 9568), which were published in the Federal Register on Thursday, December 22, 2011 (76 FR 80082), Relating to section 482 and methods to determine taxable income in connection with a cost sharing arrangement.

77 FR 3605 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

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RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

Effective January 25, 2012, and applicable beginning December 22, 2011.

26 CFR Part 1

Summary

2012-01-23; vol. 77 # 14 - Monday, January 23, 2012

77 FR 3106 - Damages Received on Account of Personal Physical Injuries or Physical Sickness

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FR Doc.	2012-1255
RIN	1545-BF81
TD	9573

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on January 23, 2012. Applicability Date: For date of applicability, see § 1.104-1(c)(3).

26 CFR Part 1

Summary

This document contains final regulations relating to the exclusion from gross income for amounts received on account of personal physical injuries or physical sickness. The final regulations reflect amendments under the Small Business Job Protection Act of 1996. The final regulations affect taxpayers receiving damages on account of personal physical injuries or physical sickness and taxpayers paying these damages.

77 FR 3108 - Dividend Equivalents From Sources Within the United States

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DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

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26 CFR Part 1

Summary

This document contains temporary regulations relating to dividend equivalents for purposes of section 871(m) of the Internal Revenue Code (Code). The regulations provide guidance to nonresident aliens and foreign corporations that hold notional principal contracts (NPCs) providing for payments determined by reference to payments of dividends from sources within the United States. 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 .

2012-01-17; vol. 77 # 10 - Tuesday, January 17, 2012

77 FR 2225 - Allocation and Apportionment of Interest Expense

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FR Doc.	2012-597
RIN	1545- BJ84
TD	9571

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on January 17, 2012. Applicability Dates: For dates of applicability, see §§ 1.861-9T(k) and 1.861-11T(h).

26 CFR Part 1

Summary

This document contains temporary regulations that provide guidance regarding the allocation and apportionment of interest expense. These temporary regulations provide guidance concerning the allocation and apportionment of interest expense by corporations owning a 10 percent or greater interest in a partnership, as well as the allocation and apportionment of interest expense using the fair market value method. These temporary regulations also update the interest allocation regulations to conform to the statutory changes made by section 216 of the legislation commonly referred to as the Education Jobs and Medicaid Assistance Act (EJMAA), enacted on August 10, 2010, affecting the affiliation of certain foreign corporations for purposes of section 864(e). These regulations affect taxpayers that allocate and apportion interest expense. The text of these temporary regulations also serves as the text of the proposed regulations (REG-113903-10) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register .

2011-12-27; vol. 76 # 248 - Tuesday, December 27, 2011

76 FR 81060 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

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FR Doc.	2011-32024
RIN	1545-BJ93
TD	9564

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on January 1, 2012. Applicability Dates: For dates of applicability of the temporary regulations, see §§ 1.162-3T, 1.162-4T, 1.162-11T, 1.165-2T, 1.167(a)-4T, 1.167(a)-7T, 1.167(a)-8T, 1.168(i)-1T, 1.168(i)-7T, 1.168(i)-8T, 1.263(a)-1T, 1.263(a)-2T, 1.263(a)-3T, 1.263(a)-6T, 1.263A-1T, and 1.1016-3T.

26 CFR Part 1

Summary

This document contains temporary regulations that provide guidance on the application of sections 162(a) and 263(a) of the Internal Revenue Code to amounts paid to acquire, produce, or improve tangible property. The temporary regulations clarify and expand the standards in the current regulations under sections 162(a) and 263(a) and provide certain bright-line tests (for example, a de minimis rule for certain acquisitions) for applying these standards. The temporary regulations also provide guidance under section 168 regarding the accounting for, and dispositions of, property subject to section 168. The temporary regulations also amend the general asset account regulations. The temporary regulations will affect all taxpayers that acquire, produce, or improve tangible property. The text of the temporary regulations also serves as the text of proposed regulations set forth in the notice of proposed rulemaking on this subject appearing elsewhere in this issue of the Federal Register .

2011-12-23; vol. 76 # 247 - Friday, December 23, 2011

76 FR 80249 - Use of Differential Income Stream as a Consideration in Assessing the Best Method

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FR Doc.	2011-32728
RIN	1545-BK72
TD	9569

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective December 19, 2011. Applicability Dates: For dates of applicability, see § 1.482-7T(l).

26 CFR Part 1

Summary

This document contains temporary regulations that implement the use of the differential income stream as a consideration in assessing the best method in connection with a cost sharing arrangement. The text of these temporary regulations also serves as part of the text of proposed regulations contained in a cross-reference notice of proposed rulemaking (REG-145474-11) published in the Proposed Rules section in this issue of the Federal Register . This document also contains final regulations that provide cross-references in the final cost sharing regulations to relevant sections of these temporary regulations.

2011-12-22; vol. 76 # 246 - Thursday, December 22, 2011

76 FR 80082 - Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

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FR Doc.	2011-32458
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on December 16, 2011. Applicability Date: For dates of applicability, see §§ 1.482-1(j)(6)(i), 1.482-2(f), 1.482-4(h), 1.482-7(l), 1.482-8(c), 1.482-9(n)(3), and 1.301-7701-1(f).

26 CFR Parts 1, 301, and 602

Summary

This document contains final regulations regarding methods to determine taxable income in connection with a cost sharing arrangement under section 482 of the Internal Revenue Code (Code). The final regulations address issues that have arisen in administering the current cost sharing regulations. The final regulations affect domestic and foreign entities that enter into cost sharing arrangements described in the final regulations.

2011-12-20; vol. 76 # 244 - Tuesday, December 20, 2011

76 FR 78816 - Tax Return Preparer Penalties Under Section 6695

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FR Doc.	2011-32487
RIN	1545-BK16
TD	9570

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective date: The final regulations are effective on December 20, 2011. Applicability date: For date of applicability, see § 1.6695-2(e).

26 CFR Part 1

Summary

This document contains final regulations that modify existing regulations related to the tax return preparer penalties under section 6695 of the Internal Revenue Code (Code). The final regulations are necessary to monitor and to improve compliance with the tax return preparer due diligence requirements of section 6695(g). The final regulations affect paid tax return preparers.

2011-12-19; vol. 76 # 243 - Monday, December 19, 2011

76 FR 78540 - Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

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FR Doc.	2011-32078
RIN	1545-BG15
TD	9565

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on December 19, 2011. Applicability Date: For dates of applicability, see § 1.368-1(e)(9)(ii).

26 CFR Part 1

Summary

This document contains final regulations that provide guidance regarding the continuity of interest requirement for corporate reorganizations. The guidance is necessary to establish the date upon which continuity of interest is measured. These regulations affect corporations and their shareholders.

76 FR 78545 - Guidance Regarding Foreign Base Company Sales Income

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FR Doc.	2011-32394
RIN	1545-BI45
TD	9563

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on December 19, 2011. Applicability Date: These regulations apply to taxable years of CFCs beginning after June 30, 2009, and for taxable years of United States shareholders in which or with which such taxable years of the CFCs end.

26 CFR Part 1

Summary

This document contains final regulations that provide guidance relating to foreign base company sales income when personal property sold by a controlled foreign corporation (CFC) is purchased, sold, manufactured, produced, constructed, grown or extracted by one or more branches of the CFC. The regulations finalize proposed regulations and withdraw temporary regulations published on December 29, 2008. These regulations, in general, affect controlled foreign corporations and their United States shareholders.

76 FR 78553 - Reporting of Specified Foreign Financial Assets

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FR Doc.	2011-32263
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on December 19, 2011. Applicability Dates: For dates of applicability, see §§ 1.6038D-1T(b), 1.6038D-2T(e), 1.6038D-3T(e), 1.6038D-4T(b), 1.6038D-5T(g), 1.6038D-7T(d), and 1.6038D-8T(g).

26 CFR Part 1

Summary

This document contains temporary regulations relating to the provisions of the Hiring Incentives to Restore Employment (HIRE) Act that require foreign financial assets to be reported to the Internal Revenue Service for taxable years beginning after March 18, 2010. In particular, the temporary regulations provide guidance relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest. The temporary regulations affect individuals required to file Form 1040, “U.S. Individual Income Tax Return,” and certain individuals required to file Form 1040-NR, “Nonresident Alien Income Tax Return.” The text of these temporary regulations also serves as the text of proposed regulations contained in a cross-reference notice of proposed rulemaking (REG-130302-10) published in the Proposed Rules section in this issue of the Federal Register .

2011-12-09; vol. 76 # 237 - Friday, December 9, 2011

76 FR 76895 - Conduit Financing Arrangements

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FR Doc.	2011-31672
RIN	1545-BH77
TD	9562

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: These regulations are effective on December 9, 2011. Applicability Date: These regulations apply to payments made on or after December 9, 2011.

26 CFR Part 1

Summary

This document contains final regulations relating to conduit financing arrangements. The final regulations apply to multiple-party financing arrangements that are effected through disregarded entities, and are necessary in order to determine which of those arrangements should be recharacterized as a conduit financing arrangement.

2011-12-05; vol. 76 # 233 - Monday, December 5, 2011

76 FR 75774 - Targeted Populations Under Section 45D(e)(2)

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FR Doc.	2011-31169
RIN	1545-BE89
TD	9560

DEPARTMENT OF TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on December 5, 2011. Applicability Dates: For dates of applicability, see § 1.45D-1(h)(3).

26 CFR Part 1

Summary

This document contains final regulations relating to how an entity serving certain targeted populations can meet the requirements to be a qualified active low-income community business for the new markets tax credit. The regulations reflect changes to the law made by the American Jobs Creation Act of 2004. The regulations will affect certain taxpayers claiming the new markets tax credit.

76 FR 75781 - Treasury Inflation-Protected Securities Issued at a Premium

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31179
RIN	1545-BK46
TD	9561

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on December 5, 2011. Applicability Date: For the date of applicability, see § 1.1275-7T(k).

26 CFR Part 1

Summary

This document contains temporary regulations that provide guidance on the tax treatment of Treasury Inflation-Protected Securities issued with more than a de minimis amount of premium. The text of these temporary regulations also serves as the text of the proposed regulations (REG-130777-11) set forth in the Proposed Rules section in this issue of the Federal Register .

2011-11-21; vol. 76 # 224 - Monday, November 21, 2011

76 FR 71878 - Corporate Reorganizations; Allocation of Basis in “All Cash D” Reorganizations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29799
RIN	1545-BJ21
TD	9558

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on November 21, 2011. Applicability Date: For dates of applicability, see § 1.358-2T(d).

26 CFR Part 1

Summary

This document contains temporary regulations regarding the determination of the basis of stock or securities in a reorganization where no stock or securities of the issuing corporation is issued and distributed in the transaction. These temporary regulations clarify that, in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction, the ability to designate the share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the issuing corporation. These temporary regulations affect corporations engaging in such transactions and their shareholders. 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 .

2011-11-18; vol. 76 # 223 - Friday, November 18, 2011

76 FR 71450 - Deduction for Qualified Film and Television Production Costs; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29922
RIN	1545-BJ24
TD	9552

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on November 18, 2011, and is applicable on October 19, 2011.

26 CFR Part 1

Summary

This document contains a correction to final and temporary regulations (TD 9552) that were published in the Federal Register on Wednesday, October 19, 2011 (76 FR 64816) relating to deductions for the cost of producing film and television productions.

2011-11-17; vol. 76 # 222 - Thursday, November 17, 2011

76 FR 71255 - Application of Section 108(e)(8) to Indebtedness Satisfied by a Partnership Interest

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29553
RIN	1545-BF27
TD	9557

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on November 17, 2011. Applicability Date: For dates of applicability, see §§ 1.108-8(d), 1.704-2(l)(1)(v), and 1.721-1(d)(4).

26 CFR Part 1

Summary

This document contains final regulations relating to the application of section 108(e)(8) of the Internal Revenue Code (Code) to partnerships and their partners. These regulations provide guidance regarding the determination of discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership's indebtedness. The final regulations also address the application of section 721 to a contribution of a partnership's recourse or nonrecourse indebtedness by a creditor to the partnership in exchange for a capital or profits interest in the partnership. Moreover, the final regulations address how a partnership's discharge of indebtedness income is allocated as a minimum gain chargeback under section 704. The regulations affect partnerships and their partners.

2011-10-20; vol. 76 # 203 - Thursday, October 20, 2011

76 FR 65110 - Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27240
RIN	1545-BH49
TD	9548

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These final regulations are effective on October 20, 2011. Applicability Date: For dates of applicability, see § 1.355-2(i).

26 CFR Part 1

Summary

This document contains final regulations regarding the distribution of stock of a controlled corporation acquired in a transaction described in section 355(a)(3)(B) of the Internal Revenue Code (Code). This action is necessary in light of amendments to section 355(b). These final regulations will affect corporations and their shareholders.

2011-10-19; vol. 76 # 202 - Wednesday, October 19, 2011

76 FR 64816 - Deduction for Qualified Film and Television Production Costs

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-26973
RIN	1545-BJ24
TD	9552

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on October 18, 2011. Applicability Dates: For dates of applicability, see § 1.181-6T.

26 CFR Part 1

Summary

This document contains final and temporary regulations relating to deductions for the cost of producing film and television productions. These temporary regulations reflect changes to the law made by the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, and affect taxpayers that produce films and television productions within the United States. 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 .

2011-10-06; vol. 76 # 194 - Thursday, October 6, 2011

76 FR 61946 - Implementation of Form 990; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-25773
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on October 6, 2011, and is applicable on September 8, 2011.

26 CFR Part 1

Summary

This document describes a correcting amendment to final regulations (TD 9549) that implement the redesigned Form 990, “Return of Organization Exempt From Income Tax”. These regulations were published in the Federal Register on Thursday, September 8, 2011 (76 FR 55746).

76 FR 61946 - Implementation of Form 990; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-25776
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on October 6, 2011, and is applicable on September 8, 2011.

26 CFR Parts 1 and 602

Summary

This document describes a correction to final regulations (TD 9549) that implement the redesigned Form 990, “Return of Organization Exempt From Income Tax”. These regulations were published in the Federal Register on Thursday, September 8, 2011 (76 FR 55746).

2011-09-30; vol. 76 # 190 - Friday, September 30, 2011

76 FR 60721 - Deduction for Qualified Film and Television Production Costs

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-24930
RIN	1545-BF94
TD	9551

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on September 29, 2011. Applicability Dates: For dates of applicability, see § 1.181-6.

26 CFR Parts 1 and 602

Summary

This document contains final regulations relating to deductions for the costs of producing qualified film and television productions. These final regulations reflect changes to the law made by the American Jobs Creation Act of 2004 and the Gulf Opportunity Zone Act of 2005, and affect persons that produce film and television productions within the United States.

2011-09-15; vol. 76 # 179 - Thursday, September 15, 2011

76 FR 56973 - Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-23598
RIN	1545-BE77
TD	9542

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on September 15, 2011 and is applicable August 16, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations and removal of temporary regulations (TD 9542) that were published in the Federal Register on Wednesday, August 17, 2011 (76 FR 50887) relating to elections to deduct start-up expenditures, organizational expenditures of corporations, and organizational expenses of partnerships. The American Jobs Creation Act of 2004 amended the Internal Revenue Code to permit the optional deduction of a limited amount of these types of expenses that are paid or incurred after October 22, 2004.

2011-09-08; vol. 76 # 174 - Thursday, September 8, 2011

76 FR 55746 - Implementation of Form 990

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22614
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on September 8, 2011. Applicability Date: For dates of applicability, see §§ 1.170A-9(k), 1.507-2(f), 1.509(a)-3(o), 1.6033-2(k), and 1.6043-3(e).

26 CFR Parts 1 and 602

Summary

This document contains final regulations necessary to implement the redesigned Form 990, “Return of Organization Exempt From Income Tax.” These final regulations make revisions to the regulations to allow for new threshold amounts for reporting compensation, to require that compensation be reported on a calendar year basis, and to modify the scope of organizations subject to information reporting requirements upon a substantial contraction. The final regulations also eliminate the advance ruling process for new organizations, change the public support computation period for publicly supported organizations to five years, consistent with the revised Form 990, and clarify that support must be reported using the organization's overall method of accounting. All tax-exempt organizations required to file annual information returns are affected by these regulations.

2011-09-07; vol. 76 # 173 - Wednesday, September 7, 2011

76 FR 55255 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22738
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on September 7, 2011 and is applicable beginning October 18, 2011.

26 CFR Part 1

Summary

This document contains corrections to final regulations (TD 9546) that were published in the Federal Register on Friday, August 19, 2011, on the definition of solid waste disposal facilities for purposes of the rules applicable to tax-exempt bonds issued by State and local governments. These regulations provide guidance to State and local governments that issue tax-exempt bonds to finance solid waste disposal facilities and to taxpayers that use those facilities.

76 FR 55255 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22739
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective September 7, 2011 and is applicable beginning October 18, 2011.

26 CFR Part 1

Summary

2011-08-30; vol. 76 # 168 - Tuesday, August 30, 2011

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22064
RIN	1545-BK25
TD	9535

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

This document contains a correction to final and temporary regulations (TD 9535), that were published in the Federal Register on Monday, July 18, 2011. These regulations provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured transactions that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22066
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

This document contains a correction to final and temporary regulations (TD 9536) that were published in the Federal Register on Monday, July 18, 2011, providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22067
RIN	1545-BK41
	REG-126519-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations that were published in the Federal Register on Monday, July 18, 2011. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results.

76 FR 53819 - Methods of Accounting Used by Corporations That Acquire the Assets of Other Corporations; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22051
RIN	1545-BD81
TD	9534

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on August 31, 2011.

26 CFR Part 1

Summary

This document describes corrections to final regulations (TD 9534) relating to the methods of accounting, including the inventory methods, to be used by corporations that acquire the assets of other corporations in certain corporate reorganizations and tax-free liquidations. These regulations were published in the Federal Register on Monday, August 1, 2011.

76 FR 53819 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22065
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 30, 2011 and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

This document contains amendments to correct errors in final and temporary regulations (TD 9536) that were published in the Federal Register on Monday, July 18, 2011, providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

2011-08-23; vol. 76 # 163 - Tuesday, August 23, 2011

76 FR 52556 - Election To Expense Certain Refineries

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21408
RIN	1545-BF05
TD	9547

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective August 22, 2011.

26 CFR Part 1 and 602

Summary

This document provides final regulations relating to the election to expense qualified refinery property under section 179C of the Internal Revenue Code (Code). These final regulations adopt the temporary regulations with certain modifications to reflect changes to the law made by the Energy Improvement and Extension Act of 2008.

2011-08-19; vol. 76 # 161 - Friday, August 19, 2011

76 FR 51878 - Modifications of Certain Derivative Contracts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21179
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on August 19, 2011, and is applicable on July 22, 2011.

26 CFR Part 1

Summary

This document describes corrections to final and temporary regulations (TD 9538) that address when a transfer or assignment of certain derivative contracts does not result in an exchange to the nonassigning counterparty for purposes of § 1.1001-1(a). These regulations were published in the Federal Register on Friday, July 22, 2011.

76 FR 51878 - Modifications of Certain Derivative Contracts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21180
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 19, 2011, and is applicable beginning July 22, 2011.

26 CFR Part 1

Summary

This document describes correcting amendments to final and temporaryregulations (TD 9538) that address when a transfer or assignment of certain derivative contracts does not result in an exchange to the nonassigning counterparty for purposes. These regulations were published in the Federal Register on Friday, July 22, 2011.

76 FR 51879 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21154
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective August 19, 2011. Applicability Date: For dates of applicability, see § 1.142(a)(6)-1(i).

26 CFR Parts 1 and 17

Summary

This document contains final regulations on the definition of solid waste disposal facilities for purposes of the rules applicable to tax-exempt bonds issued by State and local governments. These regulations provide guidance to State and local governments that issue tax-exempt bonds to finance solid waste disposal facilities and to taxpayers that use those facilities.

2011-08-17; vol. 76 # 159 - Wednesday, August 17, 2011

76 FR 50887 - Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-20872
RIN	1545-BE77
TD	9542

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on August 16, 2011. Applicability Dates: For dates of applicability, see §§ 1.195-1(d), 1.248-1(f), and 1.709-1(b)(5).

26 CFR Part 1

Summary

This document contains final regulations relating to elections to deduct start-up expenditures, organizational expenditures of corporations, and organizational expenses of partnerships. The American Jobs Creation Act of 2004 amended the Internal Revenue Code to permit the optional deduction of a limited amount of these types of expenses that are paid or incurred after October 22, 2004. The regulations affect taxpayers that pay or incur these expenses and provide guidance on how to elect to deduct the expenses in accordance with the new rules.

2011-08-10; vol. 76 # 154 - Wednesday, August 10, 2011

76 FR 49300 - Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-20224
RIN	1545-BF83
TD	9475

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 10, 2011 and is applicable on December 18, 2009.

26 CFR Part 1

Summary

This document describes a correction to final regulations (TD 9475) that were published on Friday,December 18, 2009 (74 FR 67053). The regulations provide guidance regarding the qualification of certaintransactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiringcorporation is issued and distributed in the transaction. This document also contains final regulations undersection 358 that provide guidance regarding the determination of the basis of stock or securities in a reorganizationdescribed in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued anddistributed in the transaction. This document also contains final regulations under section 1502 that governreorganizations described in section 368(a)(1)(D) involving members of a consolidated group.

76 FR 49570 - Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-19675
RIN	1545-BH67
TD	9540

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on August 10, 2011. Applicability Date: These regulations apply on August 10, 2011.

26 CFR Parts 1, 20, and 25

Summary

This document contains final regulations relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. These regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. These regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

2011-08-01; vol. 76 # 147 - Monday, August 1, 2011

76 FR 45673 - Methods of Accounting Used by Corporations That Acquire the Assets of Other Corporations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-19256
RIN	1545-BD81
TD	9534

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective date: These regulations are effective on August 31, 2011. Applicability date: For dates of applicability, see §§ 1.381(a)-1(e), 1.381(c)(4)-1(f), 1.381(c)(5)-1(f), and 1.446-1(e)(4)(iii).

26 CFR Part 1

Summary

This document contains final regulations relating to the methods of accounting, including the inventory methods, to be used by corporations that acquire the assets of other corporations in certain corporate reorganizations and tax-free liquidations. These regulations clarify and simplify the rules regarding the accounting methods to be used following these reorganizations and liquidations.

2011-07-27; vol. 76 # 144 - Wednesday, July 27, 2011

76 FR 44800 - Election of Reduced Research Credit Under Section 280C(c)(3)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18993
RIN	1545-BI09
TD	9539

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on July 27, 2011. Applicability Date: For dates of applicability, see § 1.280C-4(c).

26 CFR Part 1

Summary

This document contains final regulations that amend the regulations concerning the election to claim the reduced research credit. The final regulations simplify how taxpayers make the election and affect taxpayers that claim the reduced research credit.

2011-07-22; vol. 76 # 141 - Friday, July 22, 2011

76 FR 43891 - Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18469
RIN	1545-BH56
TD	9530

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on July 22, 2011, and is applicable beginning June 24, 2011.

26 CFR Part 1

Summary

This document describes a correction to final and temporary regulations (TD 9530) that were published in the Federal Register on Friday, June 24, 2011, regarding the determination of basis in certain United States property acquired by a controlled foreign corporation in certain nonrecognition transactions that are intended to repatriate earnings and profits of the controlled foreign corporation without U.S. income taxation.

76 FR 43892 - Modifications of Certain Derivative Contracts

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18529
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on July 22, 2011. Applicability Date: For the date of applicability, see § 1.1001-4T(d).

26 CFR Part 1

Summary

This document contains final and temporary regulations that address when a transfer or assignment of certain derivative contracts does not result in an exchange to the nonassigning counterparty for purposes of § 1.1001-1(a). The text of these temporary regulations also serves as the text of the proposed regulations (REG-109006-11) set forth in the Proposed Rules section in this issue of the Federal Register .

2011-07-18; vol. 76 # 137 - Monday, July 18, 2011

76 FR 42036 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-17916
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on July 18, 2011. Applicability Date: For dates of applicability, see § 1.901-2T(h)(3).

26 CFR Part 1

Summary

This document contains final and temporary regulations providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits. The text of these temporary regulations also serves as the text of the proposed regulations (REG-126519-11) published in the Proposed Rules section in this issue of the Federal Register .

76 FR 42036 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-17920
RIN	1545-BK25
TD	9535

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on July 18, 2011. Applicability Date: For dates of applicability, see § 1.901-1(j) and § 1.901-2(h)(2).

26 CFR Part 1

Summary

This document contains final regulations providing guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured transactions that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.

2011-07-06; vol. 76 # 129 - Wednesday, July 6, 2011

76 FR 39278 - Modification of Treasury Regulations Pursuant to Section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-16856
RIN	1545-BK28
TD	9533

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on July 6, 2011. Applicability Dates: For dates of applicability, see §§ 1.150-1T(a)(4), 1.171-1T(f), 1.197-2T(b)(7), 1.249-1T(f)(3), 1.475(a)-4T(d)(4), 1.860G-2T(g)(3), 1.1001-3T(d), (e), and (g), and 48.4101-1T(l)(5).

26 CFR Parts 1 and 48

Summary

This document contains temporary regulations that remove any reference to, or requirement of reliance on, “credit ratings” in regulations under the Internal Revenue Code (Code) and provides substitute standards of credit-worthiness where appropriate. This action is required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires Federal agencies to remove any reference to, or requirement of reliance on, credit ratings from their regulations and to substitute such standard of credit-worthiness as the agency deems appropriate for such regulations. These regulations affect persons subject to various provisions of the Code. 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 .

2011-06-24; vol. 76 # 122 - Friday, June 24, 2011

76 FR 36993 - Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15741
RIN	1545-BH56
TD	9530

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on June 24, 2011. Applicability Date: For dates of applicability, see § 1.956-1(e)(6)(vii).

26 CFR Part 1

Summary

This document contains final and temporary regulations under section 956 of the Internal Revenue Code (Code) regarding the determination of basis in certain United States property acquired by a controlled foreign corporation in certain nonrecognition transactions that are intended to repatriate earnings and profits of the controlled foreign corporation without U.S. income taxation. The regulations affect United States shareholders of a controlled foreign corporation that acquires United States property in certain nonrecognition transactions.

76 FR 36995 - Requirements for Taxpayers Filing Form 5472; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15943
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on June 24, 2011, and is applicable on June 10, 2011.

26 CFR Part 1

Summary

This document contains correcting amendments to temporary regulations (TD 9529) that were published in the Federal Register on Friday, June 10, 2011 (76 FR 33997) removing the duplicate filing requirement for Form 5472, “Information Return of a 25% Foreign-Owned U.S. corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.”

76 FR 36995 - Requirements for Taxpayers Filing Form 5472; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15946
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to temporary regulations.

This correction is effective on June 24, 2011, and is applicable on June 10, 2011.

26 CFR Part 1

Summary

This document contains corrections to temporary regulations (TD 9529) that were published in the Federal Register on Friday, June 10, 2011 (76 FR 33997) removing the duplicate filing requirement for Form 5472, “Information Return of a 25% Foreign-Owned U.S. corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.”

76 FR 36996 - Extension of Time for Filing Returns

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15902
RIN	1545-BH88
TD	9531

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and removal temporary regulations

Effective Date: These regulations are effective on June 24, 2011. Applicability Date: For dates of applicability of these regulations, see §§ 1.6081-2(h), 1.6081-6(g), and 54.6081-1(f).

26 CFR Parts 1 and 54

Summary

This document contains final regulations relating to the automatic extensions of time to file returns for partnership, trust, and estate taxpayers, and automatic extensions of time for filing returns for pension excise taxes. The objective of these final regulations is to reduce overall taxpayer burden by providing an extension period that strikes the most reasonable balance for these pass-through entities and the large number of taxpayers who require information from these entities for completion of their income tax returns.

2011-06-10; vol. 76 # 112 - Friday, June 10, 2011

76 FR 33994 - Alternative Simplified Credit Under Section 41(c)(5)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-14407
RIN	1545-BH32
TD	9528

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on June 9, 2011. Applicability Date: For dates of applicability, see §§ 1.41-6(j)(3), 1.41-8(b)(5), and 1.41-9(d).

26 CFR Part 1

Summary

This document contains final regulations relating to the election and calculation of the alternative simplified credit under section 41(c)(5) of the Internal Revenue Code (Code). The final regulations affect certain taxpayers claiming the credit under section 41. These final regulations implement changes to the credit for increasing research activities under section 41 made by the Tax Relief and Health Care Act of 2006.

76 FR 33997 - Requirements for Taxpayers Filing Form 5472

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-14468
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective June 10, 2011. Applicability Dates: For dates of applicability, see §§ 1.6038A-1T(n) and 1.6038A-2(h).

26 CFR Part 1

Summary

This document contains temporary regulations that remove the duplicate filing requirement for Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.” The temporary regulations affect certain 25-percent foreign-owned domestic corporations and certain foreign corporations that are engaged in a trade or business in the United States that are required to file Form 5472. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register .

2011-05-19; vol. 76 # 97 - Thursday, May 19, 2011

76 FR 28890 - Treatment of Property Used To Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-12279
RIN	1545-BG96
TD	9526

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective May 19, 2011. Applicability Dates: For dates of applicability, see §§ 1.367(a)-3(g)(1)(viii) and 1.367(b)-10(e).

26 CFR Part 1

Summary

This document contains final regulations under section 367 of the Internal Revenue Code (Code) relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations. The regulations finalize proposed regulations and withdraw temporary regulations published on May 27, 2008 (TD 9400). The regulations affect corporations that engage in certain triangular reorganizations involving one or more foreign corporations.

2011-05-12; vol. 76 # 92 - Thursday, May 12, 2011

76 FR 27609 - Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-11580
RIN	1545-BG54
TD	9521

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on May 12, 2011, and is applicable on April 7, 2011.

26 CFR Part 1

Summary

This document describes corrections to final regulations (TD 9521) that were published in the Federal Register on Thursday, April 7, 2011, providing guidance relating to the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Internal Revenue Code.

2011-05-06; vol. 76 # 88 - Friday, May 6, 2011

76 FR 26178 - Modifications to Treatment of Aircraft and Vessel Leasing Income

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-11164
RIN	1545-BG98
TD	9525

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on May 6, 2011. Applicability Dates: For dates of applicability, see §§ 1.367(a)-2(e)(2), 1.367(a)-4(i), 1.367(a)-5(f)(3)(ii), 1.954-2(i) and 1.956-2(e).

26 CFR Part 1

Summary

This document contains final regulations addressing the treatment of certain income and assets related to the leasing of aircraft or vessels in foreign commerce. The regulations reflect statutory changes made by the American Jobs Creation Act of 2004. In general, the regulations will affect United States shareholders of controlled foreign corporations that derive income from the leasing of aircraft or vessels in foreign commerce and U.S. persons that transfer property subject to these leases to a foreign corporation.

2011-04-13; vol. 76 # 71 - Wednesday, April 13, 2011

76 FR - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	C1-2011-4846
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

2011-04-11; vol. 76 # 69 - Monday, April 11, 2011

76 FR 19907 - Clarification of Controlled Group Qualification Rules

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-8555
RIN	1545-BG94
TD	9522

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: This regulation is effective on April 11, 2011. Applicability Date: For date of applicability, see § 1.1563-1(e).

26 CFR Part 1

Summary

This document contains a final regulation that applies to a controlled group of corporations. The regulation clarifies that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.

2011-04-07; vol. 76 # 67 - Thursday, April 7, 2011

76 FR 19268 - Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-8229
RIN	1545-BG54
TD	9521

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on April 7, 2011. Applicability Dates: For dates of applicability see §§ 1.904-2(i)(3), 1.904-4(n), 1.904-5(o)(3), 1.904-7(g)(6), and 1.904(f)-12(h)(6).

26 CFR Part 1

Summary

This document contains final regulations that provide guidance relating to the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Internal Revenue Code. Changes to the applicable law were made by the American Jobs Creation Act of 2004 (AJCA) reducing the number of section 904(d) separate categories from eight to two, effective for taxable years beginning after December 31, 2006. The final regulations provide guidance needed to comply with these changes and affect individuals and corporations claiming foreign tax credits.

2011-03-31; vol. 76 # 62 - Thursday, March 31, 2011

76 FR 17781 - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-7506
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on March 31, 2011, and is applicable on March 4, 2011.

26 CFR Part 1

Summary

This document describes correcting amends to final and temporary regulations concerning the treatment of certain intercompany gain with respect to stock owned by members of a consolidated group. These regulations provide for the redetermination of intercompany gain as excluded from gross income in certain transactions involving stock transfers between members of a consolidated group. These errors were made when the agency published final and temporary regulations (TD 9515) in the Federal Register on Friday, March 4, 2011 (76 FR 11956).

2011-03-30; vol. 76 # 61 - Wednesday, March 30, 2011

76 FR 17521 - Specified Tax Return Preparers Required To File Individual Income Tax Returns Using Magnetic Media

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-7571
RIN	1545-BJ52
TD	9518

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective March 30, 2011. Applicability Dates: In accordance with sections 7805(b)(1)(B) and (b)(2) and section 6011(e)(3), these regulations are applicable to individual income tax returns filed after December 31, 2010. See § 301.6011-7(g).

26 CFR Parts 1 and 301

Summary

This document contains final regulations on the requirement for “specified tax return preparers” to file individual income tax returns using magnetic media pursuant to section 6011(e)(3) of the Internal Revenue Code (Code). The final regulations reflect changes made to the law by the Worker, Homeownership, and Business Assistance Act of 2009. These regulations provide guidance to specified tax return preparers who prepare and file individual income tax returns. Unless an exception in these regulations applies, a tax return preparer who meets the definition of a “specified tax return preparer” must electronically file Federal income tax returns that the preparer prepares and files for individuals, trusts, and estates. These regulations provide a two-year transition period for certain specified tax return preparers.

2011-03-04; vol. 76 # 43 - Friday, March 4, 2011

76 FR 11956 - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-4846
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on March 4, 2011. Applicability Date: Section 1.1502-13(c)(6)(ii)(C), (c)(6)(ii)(D), and (c)(7)(ii), Examples 16 and 17 apply with respect to items taken into account on or after March 4, 2011.

26 CFR Part 1

Summary

This document contains final regulations concerning the treatment of certain intercompany gain with respect to stock owned by members of a consolidated group. These regulations provide for the redetermination of intercompany gain as excluded from gross income in certain transactions involving stock transfers between members of a consolidated group. The temporary regulations contained in this document are solely for the purpose of retaining the portion of the existing temporary regulations that were in the same temporary regulation section but that are not being promulgated as final regulations at this time. These regulations affect corporations filing consolidated returns.

2011-02-07; vol. 76 # 25 - Monday, February 7, 2011

76 FR 6553 - Time and Manner for Electing Capital Asset Treatment for Certain Self-Created Musical Works

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-2549
RIN	1545-BG34
TD	9514

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation and removal of temporary regulation.

Effective Date: This regulation is effective on February 7, 2011. Applicability Date: For date of applicability, see § 1.1221-3(d).

26 CFR Part 1

Summary

This document contains a final regulation that provides the time and manner rules for electing to treat the sale or exchange of a musical composition or a copyright in a musical work created by the taxpayer (or received by the taxpayer from the composition or work's creator in a transferred basis transaction) as the sale or exchange of a capital asset. The regulation reflects changes to the law made by the Tax Increase Prevention and Reconciliation Act of 2005 and the Tax Relief and Health Care Act of 2006. The regulation affects taxpayers who elect to treat gain or loss from such a sale or exchange as capital gain or loss.

2011-01-25; vol. 76 # 16 - Tuesday, January 25, 2011

76 FR - Hybrid Retirement Plans

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	C1-2010-25941
RIN	1545-BG36
TD	9505

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

76 FR 4244 - Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-1408
RIN	1545-BF85
TD	9391

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on January 25, 2011, and is applicable on April 9, 2008.

26 CFR Part 1

Summary

This document contains a correction to final regulations (TD 9391) that were published in the Federal Register on Wednesday, April 9, 2008 (73 FR 19350) providing rules under section 937(b) of the Internal Revenue Code for determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) (generally referred to in this preamble as a “territory”) and whether income is effectively connected with the conduct of a trade or business within a territory as well as providing guidance under section 932 and other provisions related to the territories.

2011-01-21; vol. 76 # 14 - Friday, January 21, 2011

76 FR 3837 - Nuclear Decommissioning Funds; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-1215
RIN	1545-BF08
TD	9512

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on January 21, 2011, and is applicable on December 23, 2010.

26 CFR Part 1

Summary

This document contains a correction to final regulations (TD 9512) that were published in the Federal Register on Thursday, December 23, 2010 (75 FR 80697) relating to deductions for contributions to trusts maintained for decommissioning nuclear power plants.

2011-01-07; vol. 76 # 5 - Friday, January 7, 2011

76 FR 1063 - Modifications of Debt Instruments

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-86
RIN	1545-BJ30
TD	9513

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: These regulations are effective on January 7, 2011. Applicability Date: For dates of applicability, see § 1.1001-3(h).

26 CFR Part 1

Summary

This document contains final regulations relating to the modification of debt instruments. The regulations clarify the extent to which the deterioration in the financial condition of the issuer is taken into account to determine whether a modified debt instrument will be recharacterized as an instrument or property right that is not debt. The regulations provide needed guidance to issuers and holders of debt instruments.

2011-01-06; vol. 76 # 4 - Thursday, January 6, 2011

76 FR 708 - Electronic Funds Transfer of Depository Taxes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2010-33357
RIN	1545-BJ13
TD	9507

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

Effective January 6, 2011.

26 CFR Parts 1, 31, 40, and 301

Summary

This document contains corrections to final and temporary regulations (TD 9507) that were published in the Federal Register on Tuesday, December 7, 2010 (75 FR 75897) providing guidance relating to Federal tax deposits (FTDs) by Electronic Funds Transfer (EFT). The temporary and final regulations provide rules under which depositors must use EFT for all FTDs and eliminate the rules regarding FTD coupons.

This is a list of United States Code sections, Statutes at Large, Public Laws, and Presidential Documents, which provide rulemaking authority for this CFR Part.

This list is taken from the Parallel Table of Authorities and Rules provided by GPO [Government Printing Office].

It is not guaranteed to be accurate or up-to-date, though we do refresh the database weekly. More limitations on accuracy are described at the GPO site.

United States Code

26 USC 1 - Tax imposed

26 USC 101 - Certain death benefits

26 USC 1017 - Discharge of indebtedness

26 USC 103 - Interest on State and local bonds

26 USC 1032 - Exchange of stock for property

26 USC 103A - Repealed.

26 USC 1059 - Corporate shareholder’s basis in stock reduced by nontaxed portion of extraordinary dividends

26 USC 1060 - Special allocation rules for certain asset acquisitions

26 USC 108 - Income from discharge of indebtedness

26 USC 1092 - Straddles

26 USC 110 - Qualified lessee construction allowances for short-term leases

26 USC 1202 - Partial exclusion for gain from certain small business stock

26 USC 1221 - Capital asset defined

26 USC 1244 - Losses on small business stock

26 USC 1248 - Gain from certain sales or exchanges of stock in certain foreign corporations

26 USC 1254 - Gain from disposition of interest in oil, gas, geothermal, or other mineral properties

26 USC 1275 - Other definitions and special rules

26 USC 1286 - Tax treatment of stripped bonds

26 USC 129 - Dependent care assistance programs

26 USC 1291 - Interest on tax deferral

26 USC 1293 - Current taxation of income from qualified electing funds

26 USC 1294 - Election to extend time for payment of tax on undistributed earnings

26 USC 1295 - Qualified electing fund

26 USC 1296 - Election of mark to market for marketable stock

26 USC 1297 - Passive foreign investment company

26 USC 1298 - Special rules

26 USC 1301 - Averaging of farm income

26 USC 132 - Certain fringe benefits

26 USC 1361 - S corporation defined

26 USC 1368 - Distributions

26 USC 1374 - Tax imposed on certain built-in gains

26 USC 1377 - Definitions and special rule

26 USC 1378 - Taxable year of S corporation

26 USC 1397D - Qualified zone property defined

26 USC 1397E - Credit to holders of qualified zone academy bonds

26 USC 1402 - Definitions

26 USC 1441 - Withholding of tax on nonresident aliens

26 USC 1443 - Foreign tax-exempt organizations

26 USC 1445 - Withholding of tax on dispositions of United States real property interests

26 USC 148 - Arbitrage

26 USC 149 - Bonds must be registered to be tax exempt; other requirements

26 USC 150 - Definitions and special rules

26 USC 1502 - Regulations

26 USC 1503 - Computation and payment of tax

26 USC 1504 - Definitions

26 USC 152 - Dependent defined

26 USC 1561 - Limitations on certain multiple tax benefits in the case of certain controlled corporations

26 USC 162 - Trade or business expenses

26 USC 163 - Interest

26 USC 165 - Losses

26 USC 166 - Bad debts

26 USC 168 - Accelerated cost recovery system

26 USC 170 - Charitable, etc., contributions and gifts

26 USC 171 - Amortizable bond premium

26 USC 179 - Election to expense certain depreciable business assets

26 USC 179A - Deduction for clean-fuel vehicles and certain refueling property

26 USC 197 - Amortization of goodwill and certain other intangibles

26 USC 199 - Income attributable to domestic production activities

26 USC 21 - Expenses for household and dependent care services necessary for gainful employment

26 USC 216 - Deduction of taxes, interest, and business depreciation by cooperative housing corporation tenant-stockholder

26 USC 221 - Interest on education loans

26 USC 23 - Renumbered

26 USC 25 - Interest on certain home mortgages

26 USC 25A - Hope and Lifetime Learning credits

26 USC 263A - Capitalization and inclusion in inventory costs of certain expenses

26 USC 267 - Losses, expenses, and interest with respect to transactions between related taxpayers

26 USC 274 - Disallowance of certain entertainment, etc., expenses

26 USC 28

26 USC 280C - Certain expenses for which credits are allowable

26 USC 280F - Limitation on depreciation for luxury automobiles; limitation where certain property used for personal purposes

26 USC 280G - Golden parachute payments

26 USC 30 - Certain plug-in electric vehicles

26 USC 301 - Distributions of property

26 USC 304 - Redemption through use of related corporations

26 USC 305 - Distributions of stock and stock rights

26 USC 324

26 USC 337 - Nonrecognition for property distributed to parent in complete liquidation of subsidiary

26 USC 338 - Certain stock purchases treated as asset acquisitions

26 USC 3401 - Definitions

26 USC 351 - Transfer to corporation controlled by transferor

26 USC 355 - Distribution of stock and securities of a controlled corporation

26 USC 357 - Assumption of liability

26 USC 358 - Basis to distributees

26 USC 367 - Foreign corporations

26 USC 38 - General business credit

26 USC 382 - Limitation on net operating loss carryforwards and certain built-in losses following ownership change

26 USC 383 - Special limitations on certain excess credits, etc.

26 USC 40 - Alcohol, etc., used as fuel

26 USC 401 - Qualified pension, profit-sharing, and stock bonus plans

26 USC 401 note - Qualified pension, profit-sharing, and stock bonus plans

26 USC 402A - Optional treatment of elective deferrals as Roth contributions

26 USC 403 - Taxation of employee annuities

26 USC 404 - Deduction for contributions of an employer to an employees’ trust or annuity plan and compensation under a deferred-payment plan

26 USC 408 - Individual retirement accounts

26 USC 408A - Roth IRAs

26 USC 409 - Qualifications for tax credit employee stock ownership plans

26 USC 41 - Credit for increasing research activities

26 USC 410 - Minimum participation standards

26 USC 411 - Minimum vesting standards

26 USC 414 - Definitions and special rules

26 USC 417 - Definitions and special rules for purposes of minimum survivor annuity requirements

26 USC 419A - Qualified asset account; limitation on additions to account

26 USC 42 - Low-income housing credit

26 USC 420 - Transfers of excess pension assets to retiree health accounts

26 USC 43 - Enhanced oil recovery credit

26 USC 441 - Period for computation of taxable income

26 USC 442 - Change of annual accounting period

26 USC 444 - Election of taxable year other than required taxable year

26 USC 446 - General rule for methods of accounting

26 USC 453 - Installment method

26 USC 453A - Special rules for nondealers

26 USC 458 - Magazines, paperbacks, and records returned after the close of the taxable year

26 USC 45D - New markets tax credit

26 USC 46 - Amount of credit

26 USC 460 - Special rules for long-term contracts

26 USC 461 - General rule for taxable year of deduction

26 USC 465 - Deductions limited to amount at risk

26 USC 466 - Repealed.

26 USC 467 - Certain payments for the use of property or services

26 USC 468A - Special rules for nuclear decommissioning costs

26 USC 468B - Special rules for designated settlement funds

26 USC 469 - Passive activity losses and credits limited

26 USC 47 - Rehabilitation credit

26 USC 471 - General rule for inventories

26 USC 472 - Last-in, first-out inventories

26 USC 475 - Mark to market accounting method for dealers in securities

26 USC 481 - Adjustments required by changes in method of accounting

26 USC 482 - Allocation of income and deductions among taxpayers

26 USC 483 - Interest on certain deferred payments

26 USC 493

26 USC 504 - Status after organization ceases to qualify for exemption under

26 USC 514 - Unrelated debt-financed income

26 USC 52 - Special rules

26 USC 527 - Political organizations

26 USC 56 - Adjustments in computing alternative minimum taxable income

26 USC 58 - Denial of certain losses

26 USC 585 - Reserves for losses on loans of banks

26 USC 597 - Treatment of transactions in which Federal financial assistance provided

26 USC 6001 - Notice or regulations requiring records, statements, and special returns

26 USC 6011 - General requirement of return, statement, or list

26 USC 6015 - Relief from joint and several liability on joint return

26 USC 6033 - Returns by exempt organizations

26 USC 6035 - Repealed.

26 USC 6038 - Information reporting with respect to certain foreign corporations and partnerships

26 USC 6038A - Information with respect to certain foreign-owned corporations

26 USC 6038B - Notice of certain transfers to foreign persons

26 USC 6039I - Returns and records with respect to employer-owned life insurance contracts

26 USC 6041 - Information at source

26 USC 6043 - Liquidating, etc., transactions

26 USC 6045 - Returns of brokers

26 USC 6046A - Returns as to interests in foreign partnerships

26 USC 6049 - Returns regarding payments of interest

26 USC 6050E - State and local income tax refunds

26 USC 6050H - Returns relating to mortgage interest received in trade or business from individuals

26 USC § 5521 to 5523 - Repealed.

26 USC 6050K - Returns relating to exchanges of certain partnership interests

26 USC 6050M - Returns relating to persons receiving contracts from Federal executive agencies

26 USC 6050P - Returns relating to the cancellation of indebtedness by certain entities

26 USC 6050S - Returns relating to higher education tuition and related expenses

26 USC 6060 - Information returns of tax return preparers

26 USC 6061 - Signing of returns and other documents

26 USC 6065 - Verification of returns

26 USC 6081 - Extension of time for filing returns

26 USC 61 - Gross income defined

26 USC 6103 - Confidentiality and disclosure of returns and return information

26 USC 6109 - Identifying numbers

26 USC 62 - Adjusted gross income defined

26 USC 6302 - Mode or time of collection

26 USC 6402 - Authority to make credits or refunds

26 USC 6411 - Tentative carryback and refund adjustments

26 USC 642 - Special rules for credits and deductions

26 USC 643 - Definitions applicable to subparts A, B, C, and?D

26 USC 645 - Certain revocable trusts treated as part of estate

26 USC 66 - Treatment of community income

26 USC 663 - Special rules applicable to

26 USC 664 - Charitable remainder trusts

26 USC 6655 - Failure by corporation to pay estimated income tax

26 USC 6662 - Imposition of accuracy-related penalty on underpayments

26 USC 6695 - Other assessable penalties with respect to the preparation of tax returns for other persons

26 USC 67 - 2-percent floor on miscellaneous itemized deductions

26 USC 672 - Definitions and rules

26 USC 679 - Foreign trusts having one or more United States beneficiaries

26 USC 6851 - Termination assessments of income tax

26 USC 701 - Partners, not partnership, subject to tax

26 USC 702 - Income and credits of partner

26 USC 703 - Partnership computations

26 USC 704 - Partner’s distributive share

26 USC 705 - Determination of basis of partner’s interest

26 USC 706 - Taxable years of partner and partnership

26 USC 707 - Transactions between partner and partnership

26 USC 708 - Continuation of partnership

26 USC 709 - Treatment of organization and syndication fees

26 USC 72 - Annuities; certain proceeds of endowment and life insurance contracts

26 USC 721 - Nonrecognition of gain or loss on contribution

26 USC 722 - Basis of contributing partner’s interest

26 USC 723 - Basis of property contributed to partnership

26 USC 724 - Character of gain or loss on contributed unrealized receivables, inventory items, and capital loss property

26 USC 731 - Extent of recognition of gain or loss on distribution

26 USC 732 - Basis of distributed property other than money

26 USC 733 - Basis of distributee partner’s interest

26 USC 734 - Adjustment to basis of undistributed partnership property where

26 USC 735 - Character of gain or loss on disposition of distributed property

26 USC 736 - Payments to a retiring partner or a deceased partner’s successor in interest

26 USC 737 - Recognition of precontribution gain in case of certain distributions to contributing partner

26 USC 741 - Recognition and character of gain or loss on sale or exchange

26 USC 742 - Basis of transferee partner’s interest

26 USC 743 - Special rules where

26 USC 751 - Unrealized receivables and inventory items

26 USC 752 - Treatment of certain liabilities

26 USC 7520 - Valuation tables

26 USC 753 - Partner receiving income in respect of decedent

26 USC 754 - Manner of electing optional adjustment to basis of partnership property

26 USC 755 - Rules for allocation of basis

26 USC 761 - Terms defined

26 USC 7654 - Coordination of United States and certain possession individual income taxes

26 USC 7701 - Definitions

26 USC 7702 - Life insurance contract defined

26 USC 7805 - Rules and regulations

26 USC 7872 - Treatment of loans with below-market interest rates

26 USC 7874 - Rules relating to expatriated entities and their foreign parents

26 USC 809 - Repealed.

26 USC 817A - Special rules for modified guaranteed contracts

26 USC 832 - Insurance company taxable income

26 USC 845 - Certain reinsurance agreements

26 USC 846 - Discounted unpaid losses defined

26 USC 848 - Capitalization of certain policy acquisition expenses

26 USC 852 - Taxation of regulated investment companies and their shareholders

26 USC 860E - Treatment of income in excess of daily accruals on residual interests

26 USC 860G - Other definitions and special rules

26 USC 863 - Special rules for determining source

26 USC 864 - Definitions and special rules

26 USC 865 - Source rules for personal property sales

26 USC 874 - Allowance of deductions and credits

26 USC 882 - Tax on income of foreign corporations connected with United States business

26 USC 883 - Exclusions from gross income

26 USC 884 - Branch profits tax

26 USC 892 - Income of foreign governments and of international organizations

26 USC 894 - Income affected by treaty

26 USC 897 - Disposition of investment in United States real property

26 USC 901 - Taxes of foreign countries and of possessions of United States

26 USC 902 - Deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation

26 USC 904 - Limitation on credit

26 USC 907 - Special rules in case of foreign oil and gas income

26 USC 911 - Citizens or residents of the United States living abroad

26 USC 924

26 USC 925

26 USC 927 - Repealed.

26 USC 934 - Limitation on reduction in income tax liability incurred to the Virgin Islands

26 USC 936 - Puerto Rico and possession tax credit

26 USC 937 - Residence and source rules involving possessions

26 USC 954 - Foreign base company income

26 USC 957 - Controlled foreign corporations; United States persons

26 USC 960 - Special rules for foreign tax credit

26 USC 963 - Repealed.

26 USC 985 - Functional currency

26 USC 987 - Branch transactions

26 USC 988 - Treatment of certain foreign currency transactions

26 USC 989 - Other definitions and special rules

29 USC 1001 note - Congressional findings and declaration of policy

Statutes at Large

103 Stat. 2373

103 Stat. 2413

114 Stat. 2763

114 Stat. 2763A-638

114 Stat. 464

115 Stat. 38

94 Stat. 1208

94 Stat. 1308

96 Stat. 324

96 Stat. 669

Public Laws

97-119

Presidential Documents

Reorganization ... 1978 Plan No. 4

The following are ALL rules, proposed rules, and notices (chronologically) published in the Federal Register relating to 26 CFR 1

2012-03-30; vol. 77 # 62 - Friday, March 30, 2012

77 FR 19154 - Allocation and Apportionment of Interest Expense; Hearing Cancellation

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-7609
RIN	1545-BJ59
	REG-113903-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of public hearing on proposed rulemaking.

The public hearing, originally scheduled for April 3, 2012 at 10 a.m. is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on proposed rulemaking that provides guidance relating to the allocation and apportionment of interest expense.

2012-03-28; vol. 77 # 60 - Wednesday, March 28, 2012

77 FR 18686 - Apportionment of Tax Items Among the Members of a Controlled Group of Corporations

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Additional Documents

type regulations.gov

FR Doc. 2012-7533

RIN

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

77 FR 18687 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-7263
RIN	1545-BJ93
TD	9564

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations; correcting amendment.

Effective Date: March 28, 2012.

26 CFR Part 1

Summary

2012-03-27; vol. 77 # 59 - Tuesday, March 27, 2012

77 FR 18145 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-7266
RIN	1545-BE18
	REG-168745-03

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking; Correction.

Effective Date: March 27, 2012.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking (REG-168745-03), which was published in the Federal Register relating to sections 162, and 263 providing guidance on the deduction and capitalization of expenditures related to tangible property.

77 FR 18145 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-7267
RIN
	REG-168745-03

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking; correcting amendment.

Effective Date: March 27, 2012 and is applicable on or after December 27, 2011.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking (REG-168745-03), which was published in the Federal Register relating to sections 162, and 263, providing guidance on the deduction and capitalization of expenditures related to tangible property.

2012-03-16; vol. 77 # 52 - Friday, March 16, 2012

77 FR 15646 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Hearing

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-6371
RIN	1545-BE18
	REG-168745-03

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Change date of public hearing on proposed rulemaking.

The public hearing originally scheduled for Wednesday, April 25, 2012, at 10 a.m. is rescheduled for Wednesday, May 9, 2012, at 10 a.m. Written or electronically submitted public comments along with requests to speak and outlines of topics to be discussed at the public hearing must be received by Tuesday, April 17, 2012.

26 CFR Part 1

Summary

This document changes the date of a public hearing on proposed regulations relating to the deduction and capitalization of expenditures related to tangible property.

2012-03-15; vol. 77 # 51 - Thursday, March 15, 2012

77 FR 15319 - Treasury Inflation-Protected Securities Issued at a Premium; Hearing Cancellation

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Additional Documents

type	regulations.gov
FR Doc.	2012-6212
RIN	1545-BK45
	REG-130777-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of public hearing on proposed rulemaking.

The public hearing originally scheduled for March 28, 2012 at 10 a.m., is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on proposed regulations (REG-130777-11), providing guidance on the tax treatment of Treasury Inflation-Protected Securities issued with more than a de minimis amount of premium.

2012-03-14; vol. 77 # 50 - Wednesday, March 14, 2012

77 FR 15003 - Passive Activity Losses and Credits Limited; Hearing

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Additional Documents

type	regulations.gov
FR Doc.	2012-6068
RIN	1545-BJ33
	REG-109369-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is being held on Monday, April 30, 2012, at 10 a.m. The IRS must receive outlines of the topics to be discussed at the public hearing by April 9, 2012.

26 CFR Part 1

Summary

This document provides notice of public hearing on proposed rulemaking regarding the definition of an “interest in a limited partnership as a limited partner” for purposes of determining whether a taxpayer materially participates in an activity under section 469 of the Internal Revenue Code. These proposed regulations affect individuals who are partners in partnerships.

2012-03-09; vol. 77 # 47 - Friday, March 9, 2012

77 FR 14321 - Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension Plans; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-5715
RIN	1545-BJ55
	REG-110980-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendments.

This correction is effective on March 9, 2012 and is applicable on February 3, 2012.

26 CFR Part 1

Summary

This document contains a correction to the notice of proposed rulemaking andnotice of public hearing (REG-110980-10) that was published in the Federal Register on Friday, February 3, 2012 (77 FR 5454), providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans.

2012-03-08; vol. 77 # 46 - Thursday, March 8, 2012

77 FR 13968 - Dividend Equivalents From Sources Within the United States; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-5315
RIN	1545-BK53
TD	9572

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations; correcting amendment.

Effective Date: March 8, 2012 and is applicable January 23, 2012.

26 CFR Part 1

Summary

This document contains corrections to temporary regulations (TD 9572), relating to dividend equivalents from sources within the United States.

77 FR 13996 - Determination of Governmental Plan Status; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-5595
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a correction of notice of public hearing on an advance notice of proposed rulemaking; correction.

26 CFR Part 1

Summary

This document corrects a correction to a notice of public hearing on an advance proposed rulemaking (REG-157714-06) that was published in the Federal Register on Thursday, March 1, 2012 (77 FR 12514) relating to the determination of governmental plans.

77 FR 13996 - Indian Tribal Government Plans; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-5597
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a correction of notice of public hearing on an advance notice of proposed rulemaking; correction.

26 CFR Part 1

Summary

This document corrects a correction to a notice of public hearing on an advance proposed rulemaking (REG-133223-08) that was published in the Federal Register on Wednesday, February 29, 2012 (77 FR 12226) relating to Indian tribal government plans.

2012-03-01; vol. 77 # 41 - Thursday, March 1, 2012

77 FR 12514 - Determination of Governmental Plan Status; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-4905
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on an advance notice of proposed rulemaking; correction.

26 CFR Part 1

Summary

This document corrects a notice of public hearing on an advance proposed rulemaking (REG-157714-06) that was published in the Federal Register on Friday, February 3, 2012 (77 FR 5442) relating to the determination of governmental plans.

2012-02-29; vol. 77 # 40 - Wednesday, February 29, 2012

77 FR 12227 - Indian Tribal Government Plans; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-4850
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

This document corrects a notice of public hearing on an advance proposed rulemaking (REG-133233-08) that was published in the Federal Register on Friday, February 3, 2012 (77 FR 5442) relating to Indian tribal government plans.

2012-02-22; vol. 77 # 35 - Wednesday, February 22, 2012

77 FR 10422 - Reporting of Specified Foreign Financial Assets; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-3904
RIN	1545-BJ69
	REG-130302-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction notice.

Effective Date: December 19, 2011.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking (REG-130302-10), which was published in the Federal Register on Monday, December 19, 2011 (76 FR 78594), relating to the reporting of specified foreign financial assets.

2012-02-21; vol. 77 # 34 - Tuesday, February 21, 2012

77 FR 9844 - Allocation and Apportionment of Interest Expense; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2012-3855
RIN	1545-BJ84
TD	9571

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on February 21, 2012, and is applicable on January 17, 2012.

26 CFR Part 1

Summary

77 FR 9845 - Reporting of Specified Foreign Financial Assets; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3935
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

Effective date: This correction is effective February 21, 2012, and is applicable beginning December 19, 2011.

26 CFR Part 1

Summary

77 FR 9845 - Reporting of Specified Foreign Financial Assets; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3936
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final rule; correction.

Effective Date: This correction is effective February 21, 2012, and is applicable beginning December 19, 2011.

26 CFR Part 1

Summary

77 FR 9846 - Source of Income From Qualified Fails Charges

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3909
RIN	1545-BJ78
TD	9579

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date. These regulations are effective on February 21, 2012. Applicability Date. For the date of applicability, see § 1.863-10(g).

26 CFR Part 1

Summary

77 FR 9877 - Reporting of Specified Foreign Financial Assets; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3933
RIN	1545-BJ69
	REG-130302-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Proposed rule; correction.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking (REG-130302-10), which was published in the Federal Register on Monday, December 19, 2011, relating to the reporting of specified foreign financial assets.

2012-02-15; vol. 77 # 31 - Wednesday, February 15, 2012

77 FR 8753 - Furnishing Identifying Number of Tax Return Preparer

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3576
RIN	1545-BK37
	REG-124791-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by May 15, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations that provide guidance on the eligibility of tax return preparers to obtain a preparer tax identification number (PTIN). These proposed regulations expand the list of tax return preparers who may obtain and renew a PTIN. The proposed regulations additionally provide guidance concerning those tax forms submitted to the Internal Revenue Service that are considered returns of tax or claims for refund of tax for purposes of the requirement to obtain a PTIN and related provisions. This document also invites comments from the public regarding these proposed regulations.

77 FR 9022 - Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-2979
RIN	1545-BK68
	REG-121647-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by April 30, 2012. Requests to speak and outlines of topics to be discussed at the public hearing scheduled for May 15, 2012, at 10 a.m. must be received by May 1, 2012.

26 CFR Parts 1 and 301

Summary

This document contains proposed regulations under chapter 4 of Subtitle A (sections 1471 through 1474) of the Internal Revenue Code of 1986 (Code) regarding information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities. These regulations affect persons making certain U.S.-related payments to FFIs and other foreign entities and payments by FFIs to other persons. This document also provides a notice of a public hearing on these proposed regulations.

2012-02-14; vol. 77 # 30 - Tuesday, February 14, 2012

77 FR 8120 - Definition of a Taxpayer

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3352
RIN	1545-BF73
TD	9576

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on February 14, 2012. Applicability Dates: For dates of applicability, see § 1.901-2(h)(4).

26 CFR Part 1

Summary

77 FR 8127 - Foreign Tax Credit Splitting Events

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3356
RIN	1545-BK50
TD	9577

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

26 CFR Part 1

Summary

77 FR 8143 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3351
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on February 14, 2012 and is applicable beginning December 22, 2011.

26 CFR Part 1

Summary

77 FR 8143 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3353
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of correcting amendments.

This correction is effective on February 14, 2012, and is applicable beginnning December 22, 2011.

26 CFR Part 1

Summary

77 FR 8184 - Foreign Tax Credit Splitting Events

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-3350
RIN	1545-BK49
	REG-132736-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Comments and requests for a public hearing must be received by May 14, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section in this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to a new provision of the Internal Revenue Code (Code) that addresses situations in which foreign income taxes have been separated from the related income. Those regulations are necessary to provide guidance on applying the new statutory provision, which was enacted as part of legislation commonly referred to as the Education Jobs and Medicaid Assistance Act (EJMAA) on August 10, 2010. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.

2012-02-07; vol. 77 # 25 - Tuesday, February 7, 2012

77 FR 6005 - Application for Recognition as a 501(c)(29) Organization

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-2338
RIN	1545-BK64
TD	9574

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on February 7, 2012. Applicability Date: For date of applicability, see § 1.501(c)(29)-1T(c).

26 CFR Part 1

Summary

77 FR 6027 - Application for Recognition as a 501(c)(29) Organization

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-2339
RIN	1545-BK63
	REG-135071-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Written or electronic comments and requests for a public hearing must be received by April 9, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register are temporary regulations authorizing the IRS to prescribe the procedures by which a qualified nonprofit health insurance issuer participating in the Consumer Operated and Oriented Plan program, established by the Centers for Medicare and Medicaid Services, may apply for recognition as a tax-exempt organization under the Internal Revenue Code. The text of those regulations also serves as the text of these proposed regulations.

2012-02-06; vol. 77 # 24 - Monday, February 6, 2012

77 FR - Dividend Equivalents From Sources Within the United States

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	C1-2012-1234
RIN	1545-BK53
TD	9572

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

2012-02-03; vol. 77 # 23 - Friday, February 3, 2012

77 FR 5442 - Determination of Governmental Plan Status

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-2499
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on advanced notice of proposed rulemaking.

The public hearing is scheduled for Monday, July 9, 2012, at 10 a.m. in the auditorium of the Internal Revenue Building. The IRS must receive outlines of the topics to be discussed at the public hearing by June 18, 2012.

26 CFR Part 1

Summary

This document announces a public hearing on an advance notice of proposed rulemaking, (REG-157714-06) relating to the determination of governmental plans. This notice supersedes the notice of public hearing published in the Federal Register on Monday, January 23, 2012 (77 FR 3202) that announced a public hearing for June 5, 2012. This notice also extends the comment period for the submission of public comments.

77 FR 5442 - Indian Tribal Government Plans

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Additional Documents

type	regulations.gov
FR Doc.	2012-2502
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on advance notice of proposed rulemaking.

The public hearing is scheduled for Tuesday, July 10, 2012, at 10 a.m. in the auditorium of the Internal Revenue Building. The IRS must receive outlines of the topics to be discussed at the public hearing by June 18, 2012.

26 CFR Part 1

Summary

This document announces a public hearing on an advance notice of proposed rulemaking, (REG-133223-08) relating to Indian tribal government plans. This notice supersedes the notice of public hearing published in the Federal Register on Monday, January 23, 2012 (77 FR 3210) that announced a public hearing for June 5, 2012. This notice also extends the public comment period for submission of public comments.

77 FR 5443 - Longevity Annuity Contracts

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Additional Documents

type	regulations.gov
FR Doc.	2012-2340
RIN	1545-BK23
	REG-115809-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by May 3, 2012. Outlines of topics to be discussed at the public hearing scheduled for June 1, 2012 must be received by May 11, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations relating to the purchase of longevity annuity contracts under tax-qualified defined contribution plans under section 401(a) of the Internal Revenue Code (Code), section 403(b) plans, individual retirement annuities and accounts (IRAs) under section 408, and eligible governmental section 457 plans. These regulations will provide the public with guidance necessary to comply with the required minimum distribution rules under section 401(a)(9). The regulations will affect individuals for whom a longevity annuity contract is purchased under these plans and IRAs (and their beneficiaries), sponsors and administrators of these plans, trustees and custodians of these IRAs, and insurance companies that issue longevity annuity contracts under these plans and IRAs. This document also provides a notice of a public hearing on these proposed regulations.

77 FR 5454 - Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension Plans

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-2341
RIN	1545-BJ55
	REG-110980-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by May 3, 2012. Outlines of topics to be discussed at the public hearing scheduled for June 1, 2012, must be received by May 11, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations providing guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These proposed regulations would change the regulations regarding the minimum present value requirements for defined benefit plan distributions to permit plans to simplify the treatment of certain optional forms of benefit that are paid partly in the form of an annuity and partly in a more accelerated form. These regulations would affect sponsors, administrators, participants, and beneficiaries of defined benefit pension plans. This document also provides a notice of a public hearing on these proposed regulations.

2012-01-25; vol. 77 # 16 - Wednesday, January 25, 2012

77 FR 3605 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-894
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final rule; correction.

Effective January 25, 2012, and applicable beginning December 22, 2011.

26 CFR Part 1

Summary

77 FR 3605 - Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-895
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

Effective January 25, 2012, and applicable beginning December 22, 2011.

26 CFR Part 1

Summary

2012-01-23; vol. 77 # 14 - Monday, January 23, 2012

77 FR 3106 - Damages Received on Account of Personal Physical Injuries or Physical Sickness

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1255
RIN	1545-BF81
TD	9573

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on January 23, 2012. Applicability Date: For date of applicability, see § 1.104-1(c)(3).

26 CFR Part 1

Summary

77 FR 3108 - Dividend Equivalents From Sources Within the United States

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1234
RIN	1545-BK53

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

26 CFR Part 1

Summary

77 FR 3202 - Dividend Equivalents From Sources Within the United States

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1231
RIN	1545-BJ56
	REG-120282-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

Written or electronic comments must be received by April 6, 2012. Outlines of topics to be discussed at the public hearing scheduled for April 27, 2012, at 10 a.m., must be received by April 6, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance on the definition of the term “specified notional principal contract” for purposes of section 871(m) of the Internal Revenue Code (Code) beginning after March 18, 2012 through December 31, 2012. The text of those regulations also serves as the text of the proposed regulations. The preamble to the temporary regulations explains the amendments added by the temporary regulations. The preamble to this notice of proposed rulemaking explains the proposed regulations, which provide guidance to nonresident aliens and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to payments of dividends from sources within the United States. This document also provides a notice of a public hearing on these proposed regulations.

77 FR 3202 - Determination of Governmental Plan Status

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1253
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is scheduled for Tuesday, June 5, 2012, at 10 a.m. in the auditorium of the Internal Revenue Building. The IRS must receive outlines of the topics to be discussed at the public hearing by February 6, 2012.

26 CFR Part 1

Summary

This document announces a public hearing on proposed regulations, (REG-157714-06) relating to the determination of governmental plans.

77 FR 3210 - Indian Tribal Government Plans

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1252
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

26 CFR Part 1

Summary

This document announces a public hearing on proposed regulations, (REG-133223-08) relating to Indian tribal government plans.

77 FR 3210 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Hearing

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-1256
RIN	1545-BE18
	REG-168745-03

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Change of date of public hearing on proposed rulemaking.

The public hearing originally scheduled for Thursday, April 4, 2012, at 10 a.m. is rescheduled for Wednesday, April 25, 2012, at 10 a.m. Written or electronically submitted public comments are due by March 26, 2012. Requests to speak and outlines of topics to be discussed at the public hearing must be received by March 21, 2012.

26 CFR Part 1

Summary

This document changes the date of a public hearing on proposed regulations relating to the deduction and capitalization of expenditures related to tangible property.

2012-01-17; vol. 77 # 10 - Tuesday, January 17, 2012

77 FR 2225 - Allocation and Apportionment of Interest Expense

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-597
RIN	1545- BJ84
TD	9571

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on January 17, 2012. Applicability Dates: For dates of applicability, see §§ 1.861-9T(k) and 1.861-11T(h).

26 CFR Part 1

Summary

77 FR 2240 - Allocation and Apportionment of Interest Expense

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2012-595
RIN	1545-BJ59
	REG-113903-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

Written or electronic comments must be received by March 13, 2012. Outlines of topics to be discussed at the public hearing scheduled for April 3, 2012, at 10 a.m. must be received by March 13, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section in this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance relating to the allocation and apportionment of interest expense. The temporary regulations provide guidance concerning the allocation and apportionment of interest expense by corporations owning a 10 percent or greater interest in a partnership, as well as the allocation and apportionment of interest expense using the fair market value asset method. The temporary regulations also update the interest allocation regulations to conform to the changes made to the applicable law by the legislation commonly referred to as the Education Jobs and Medicaid Assistance Act (EJMAA), enacted on August 10, 2010 (Pub. L. 111-226, 124 Stat. 2389 (2010)), which affect corporations owning certain foreign corporations engaged in the conduct of a trade or business in the United States. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations. This document also provides a notice of public hearing on these proposed regulations.

2011-12-27; vol. 76 # 248 - Tuesday, December 27, 2011

76 FR 81060 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32024
RIN	1545-BJ93
TD	9564

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

26 CFR Part 1

Summary

76 FR 81128 - Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32246
RIN	1545-BE18
	REG-168745-03

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations, notice of public hearing, and withdrawal of previously proposed regulations.

Written and/or electronic comments and requests for a public hearing must be received by March 26, 2012. Requests to speak and outlines of topics to be discussed at the public hearing scheduled for April 4, 2012 at 10 a.m., must be received by March 21, 2012.

26 CFR Part 1

Summary

Appearing elsewhere in this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance on the application of sections 162(a) and 263(a) of the Internal Revenue Code (Code) to amounts paid to acquire, produce, or improve tangible property. The temporary regulations clarify and expand the standards in the current regulations under sections 162(a) and 263(a), and provide certain bright-line tests (for example, a de minimis rule for certain acquisitions) for applying these standards. The temporary regulations also provide guidance under section 168 regarding the accounting for, and dispositions of, property subject to section 168. The temporary regulations also amend the general asset account regulations. The temporary regulations will affect all taxpayers that acquire, produce, or improve tangible property. The text of the temporary regulations published in the Federal Regulations also serves as the text of these proposed regulations. This document also provides notice of public hearing on these proposed regulations and withdraws the proposed regulations published in the Federal Register on March 10, 2008 (73 FR 47).

2011-12-23; vol. 76 # 247 - Friday, December 23, 2011

76 FR 80249 - Use of Differential Income Stream as a Consideration in Assessing the Best Method

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32728
RIN	1545-BK72
TD	9569

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective December 19, 2011. Applicability Dates: For dates of applicability, see § 1.482-7T(l).

26 CFR Part 1

Summary

76 FR 80309 - Use of Differential Income Stream as an Application of the Income Method and as a Consideration in Assessing the Best Method

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32730
RIN	1545-BK71
	REG-145474-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations and notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by March 22, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , temporary regulations provide guidance on how an analysis of the differential income stream may provide a best method consideration for evaluating an application of the income method to determine taxable income in connection with a cost sharing arrangement. The text of those regulations also serves as the text of regulations that are proposed by cross-reference to the temporary regulations. This document also contains proposed regulations providing guidance on the use of the differential income stream as a specified application of the income method to determine taxable income in connection with a cost sharing arrangement.

2011-12-22; vol. 76 # 246 - Thursday, December 22, 2011

76 FR 80082 - Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32458
RIN	1545-BI47
TD	9568

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

26 CFR Parts 1, 301, and 602

Summary

2011-12-20; vol. 76 # 244 - Tuesday, December 20, 2011

76 FR 78816 - Tax Return Preparer Penalties Under Section 6695

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32487
RIN	1545-BK16
TD	9570

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective date: The final regulations are effective on December 20, 2011. Applicability date: For date of applicability, see § 1.6695-2(e).

26 CFR Part 1

Summary

2011-12-19; vol. 76 # 243 - Monday, December 19, 2011

76 FR 78540 - Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32078
RIN	1545-BG15
TD	9565

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on December 19, 2011. Applicability Date: For dates of applicability, see § 1.368-1(e)(9)(ii).

26 CFR Part 1

Summary

76 FR 78545 - Guidance Regarding Foreign Base Company Sales Income

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32394
RIN	1545-BI45
TD	9563

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

26 CFR Part 1

Summary

76 FR 78553 - Reporting of Specified Foreign Financial Assets

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32263
RIN	1545-BK17
TD	9567

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

26 CFR Part 1

Summary

76 FR 78591 - Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32079
RIN	1545-BK43
	REG-124627-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by March 19, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations concerning the continuity of interest requirement for corporate reorganizations. The guidance is necessary to clarify the manner in which the continuity of interest requirement is measured in particular circumstances. The proposed regulations affect corporations and their shareholders.

76 FR 78594 - Reporting of Specified Foreign Financial Assets

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32254
RIN	1545-BJ69
	REG-130302-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Written or electronic comments and requests for a public hearing must be received by March 19, 2012. Comments on the collection of information should be received by February 17, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the Internal Revenue Service is issuing temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest. The text of the temporary regulations also serves as the text of these proposed regulations. This notice of proposed rulemaking also includes a proposed regulation setting forth requirements for certain domestic entities to report foreign financial assets in the same manner as an individual.

2011-12-16; vol. 76 # 242 - Friday, December 16, 2011

76 FR 78182 - Application of the Segregation Rules to Small Shareholders; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32313
RIN	1545-BK03
	REG-149625-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains a correction to notice of proposed rulemaking (REG-149625-10) that was published in the Federal Register on Wednesday, November 23, 2011 (76 FR 72362) providing guidance regarding the application of the segregation rules to public groups under section 382 of the Internal Revenue Code (Code).

76 FR 78182 - Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32316
RIN	1545-BK05
	REG-102988-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a notice of proposed rulemaking and notice of public hearing.

26 CFR Part 1

Summary

This document contains a correction to a notice of proposed rulemaking and notice of public hearing (REG-102988-11) that was published in the Federal Register on Friday, November 25, 2011 (76 FR 72652) relating to reporting by brokers for transactions related to debt instruments and options.

76 FR 78183 - Section 67 Limitations on Estates or Trusts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-32280
RIN	1545-BF80
	REG-128224-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a cancellation of notice of public hearing on proposed rulemaking.

26 CFR Part 1

Summary

This document contains a correction to a cancellation of notice of public hearing on proposed rulemaking (REG-128224-06) providing guidance on which costs incurred by estates or trusts other than grantor trusts (non-grantor trusts) are subject to the 2-percent floor for miscellaneous itemized deductions under section 67(a) of the Internal Revenue Code (Code). The document was published in the Federal Register on Tuesday, December 13, 2011 (76 FR 77454).

2011-12-13; vol. 76 # 239 - Tuesday, December 13, 2011

76 FR 77454 - New Markets Tax Credit Non-Real Estate Investments; Hearing Cancellation

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31855
RIN	1545-BF80
	REG-128224-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of public hearing on proposed rulemaking.

The public hearing, originally scheduled for December 19, 2011 at 10 a.m., is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on proposed rulemaking providing guidance on which costs incurred by estates or trusts other than grantor trusts (non-grantor trusts) are subject to the 2-percent floor for miscellaneous itemized deductions under section 67(a) of the Internal Revenue Code (Code).

2011-12-09; vol. 76 # 237 - Friday, December 9, 2011

76 FR 76895 - Conduit Financing Arrangements

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31672
RIN	1545-BH77
TD	9562

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: These regulations are effective on December 9, 2011. Applicability Date: These regulations apply to payments made on or after December 9, 2011.

26 CFR Part 1

Summary

2011-12-08; vol. 76 # 236 - Thursday, December 8, 2011

76 FR 76633 - Indian Tribal Governmental Plans; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31463
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to advance notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains corrections to advance notice of proposed rulemaking (REG-133223-08) that describes the rules the Treasury Department and IRS are considering proposing relating to the determination of whether a plan of an Indian Tribal government is a governmental plan within the meaning of section 414(d) and contains an appendix that includes a draft notice of proposed rulemaking on which the Treasury Department and IRS invite comments from the public. The document was published in the Federal Register on Tuesday, November 8, 2011 (76 FR 69188).

76 FR 76633 - Determination of Governmental Plan Status; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31464
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to advance notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains corrections to advance notice of proposed rulemaking (REG-157714-06) that describes the rules that the Treasury Department and IRS are considering proposing relating to the determination of whether a plan is a governmental planwithin the meaning of section 414(d) and contains an appendix that includes a draft notice of proposed rulemaking on which the Treasury Department and IRS invite comments from the public. The document was published in the Federal Register on Tuesday, November 8, 2011(76 FR 69172).

2011-12-05; vol. 76 # 233 - Monday, December 5, 2011

76 FR 75774 - Targeted Populations Under Section 45D(e)(2)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31169
RIN	1545-BE89
TD	9560

DEPARTMENT OF TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on December 5, 2011. Applicability Dates: For dates of applicability, see § 1.45D-1(h)(3).

26 CFR Part 1

Summary

76 FR 75781 - Treasury Inflation-Protected Securities Issued at a Premium

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31179
RIN	1545-BK46
TD	9561

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective on December 5, 2011. Applicability Date: For the date of applicability, see § 1.1275-7T(k).

26 CFR Part 1

Summary

76 FR 75829 - Treasury Inflation-Protected Securities Issued at a Premium

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-31176
RIN	1545-BK45
	REG-130777-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

Written or electronic comments must be received by March 5, 2012. Outlines of topics to be discussed at the public hearing scheduled for March 28, 2012, must be received by March 7, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance on the tax treatment of Treasury Inflation-Protected Securities issued with more than a de minimis amount of premium. The text of those regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.

2011-11-28; vol. 76 # 228 - Monday, November 28, 2011

76 FR 72875 - Passive Activity Losses and Credits Limited

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-30611
RIN	1545-BJ33
	REG-109369-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by February 27, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations regarding the definition of an “interest in a limited partnership as a limited partner” for purposes of determining whether a taxpayer materially participates in an activity under section 469 of the Internal Revenue Code (Code). These proposed regulations affect individuals who are partners in partnerships.

2011-11-25; vol. 76 # 227 - Friday, November 25, 2011

76 FR 72652 - Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-30383
RIN	1545-BK05
	REG-102988-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by February 23, 2012. Outlines of topics to be discussed at the public hearing scheduled for Friday, March 16, 2012, must be received by Friday, February 24, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations relating to reporting by brokers for transactions related to debt instruments and options. The proposed regulations reflect changes in the law made by the Energy Improvement and Extension Act of 2008 (the Act) that require brokers when reporting the sale of securities to the IRS to include the customer's adjusted basis in the sold securities and to classify any gain or loss as long-term or short-term. The proposed regulations also implement the Act's requirement that a broker report gross proceeds from a sale or closing transaction with respect to certain options. In addition, this document contains proposed regulations that implement reporting requirements for a transfer of a debt instrument or an option to another broker and for an organizational action that affects the basis of a debt instrument or option. This document also provides for a notice of a public hearing on these proposed regulations.

2011-11-23; vol. 76 # 226 - Wednesday, November 23, 2011

76 FR 72362 - Application of the Segregation Rules to Small Shareholders

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-30290
RIN	1545-BK03
	REG-149625-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by February 21, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations under section 382 of the Internal Revenue Code (Code). These proposed regulations provide guidance regarding the application of the segregation rules to public groups under section 382 of the Code. These regulations affect corporations.

76 FR 72367 - Income of Foreign Governments and International Organizations; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-30171
RIN	1545-BG08
	REG-146537-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed regulations.

26 CFR Parts 1 and 602

Summary

This document contains corrections to a notice of proposed regulations that were published in the Federal Register on Thursday, November 3, 2011. These regulations provide guidance relating to the taxation of the income of foreign governments from investments in the United States. The regulations affect foreign governments that derive income from sources within the United States.

2011-11-21; vol. 76 # 224 - Monday, November 21, 2011

76 FR 71878 - Corporate Reorganizations; Allocation of Basis in “All Cash D” Reorganizations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29799
RIN	1545-BJ21
TD	9558

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on November 21, 2011. Applicability Date: For dates of applicability, see § 1.358-2T(d).

26 CFR Part 1

Summary

76 FR 71919 - Corporate Reorganizations; Allocation of Basis in “All Cash D” Reorganizations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29794
RIN	1545-BJ21
	REG-101273-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rule making by cross-reference to temporary regulations.

Written or electronic comments and requests for a public hearing must be received by February 21, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance regarding the determination of the basis of stock or securities in a reorganization where no stock or securities of the issuing corporation is issued and distributed in the transaction. These regulations clarify that, in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction, the ability to designate the share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the issuing corporation. These regulations affect corporations engaging in such transactions and their shareholders. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.

2011-11-18; vol. 76 # 223 - Friday, November 18, 2011

76 FR 71450 - Deduction for Qualified Film and Television Production Costs; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29922
RIN	1545-BJ24
TD	9552

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on November 18, 2011, and is applicable on October 19, 2011.

26 CFR Part 1

Summary

2011-11-17; vol. 76 # 222 - Thursday, November 17, 2011

76 FR 71255 - Application of Section 108(e)(8) to Indebtedness Satisfied by a Partnership Interest

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-29553
RIN	1545-BF27
TD	9557

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on November 17, 2011. Applicability Date: For dates of applicability, see §§ 1.108-8(d), 1.704-2(l)(1)(v), and 1.721-1(d)(4).

26 CFR Part 1

Summary

2011-11-08; vol. 76 # 216 - Tuesday, November 8, 2011

76 FR 69172 - Determination of Governmental Plan Status

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-28853
RIN	1545-BG43
	REG-157714-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Advance notice of proposed rulemaking.

Written or electronic comments must be received by February 6, 2012.

26 CFR Part 1

Summary

The Treasury Department and IRS anticipate issuing regulations under section 414(d) of the Internal Revenue Code (Code) to define the term “governmental plan.” This document describes the rules that the Treasury Department and IRS are considering proposing relating to the determination of whether a plan is a governmental plan within the meaning of section 414(d) and contains an appendix that includes a draft notice of proposed rulemaking on which the Treasury Department and IRS invite comments from the public. This document applies to sponsors of, and participants and beneficiaries in, employee benefit plans that are determined to be governmental plans.

76 FR 69188 - Indian Tribal Governmental Plans

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-28858
RIN	1545-BI19
	REG-133223-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Advance notice of proposed rulemaking.

Written or electronic comments must be received by February 6, 2012.

26 CFR Part 1

Summary

The Treasury Department and IRS anticipate issuing regulations under section 414(d) of the Internal Revenue Code (Code) to define the term “governmental plan.” This document describes the rules the Treasury Department and IRS are considering proposing relating to the determination of whether a plan of an Indian tribal government is a governmental plan within the meaning of section 414(d) and contains an appendix that includes a draft notice of proposed rulemaking on which the Treasury Department and IRS invite comments from the public. This document applies to sponsors of, and participants and beneficiaries in, employee benefit plans of Indian tribal governments.

2011-11-04; vol. 76 # 214 - Friday, November 4, 2011

76 FR 68370 - Tax Accounting Elections on Behalf of Foreign Corporations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-28658
RIN	1545-BI63
	REG-114749-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Withdrawal of notice of proposed rulemaking and notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by February 2, 2012.

26 CFR Part 1

Summary

These proposed regulations would clarify the rules for controlling domestic shareholders to adopt or change a method of accounting or taxable year on behalf of a foreign corporation. The regulations affect United States persons that own stock in certain foreign corporations.

76 FR 68373 - Tax Return Preparer Penalties Under Section 6695; Hearing Cancellation

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-28660
RIN	1545-BK16
	REG-140280-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of proposed rulemaking and notice of public hearing.

The public hearing, originally scheduled for November 7, 2011 at 10 a.m., is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on notice of proposed rulemaking and notice of public hearing (REG-140280-09) that would modify existing regulations related to the tax return preparer penalties under section 6695 of the Internal Revenue Code.

2011-11-03; vol. 76 # 213 - Thursday, November 3, 2011

76 FR 68119 - Income of Foreign Governments and International Organizations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-28531
RIN	1545-BG08
	REG-146537-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by February 1, 2012.

26 CFR Parts 1 and 602

Summary

This document contains proposed Income Tax Regulations that provide guidance relating to the taxation of the income of foreign governments from investments in the United States under section 892 of the Internal Revenue Code of 1986 (Code). The regulations will affect foreign governments that derive income from sources within the United States.

2011-10-26; vol. 76 # 207 - Wednesday, October 26, 2011

76 FR 66239 - Effect of Election on Corporation

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27631
RIN	1545-BF24
	REG-158677-05

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Withdrawal of notice of proposed rulemaking.

26 CFR Parts 1

Summary

This document withdraws the proposed regulation seeking to clarify that if a bank is an S corporation within the meaning of section 1361(a)(1), its status as an S corporation does not affect the applicability of the special rules for banks under the Internal Revenue Code.

2011-10-25; vol. 76 # 206 - Tuesday, October 25, 2011

76 FR 66011 - Modifications of Certain Derivative Contracts; Hearing Cancellation

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27573
RIN	1545-BK13
	REG-109006-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of public hearing on notice of proposed rulemaking by cross-reference to temporary regulations.

The public hearing, originally scheduled for October 27, 2011 at 10 a.m., is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on notice of proposed rulemaking by cross-reference to temporary regulations relating to whether an exchange for purposes of § 1.1001-1(a) occurs for the nonassigning counterparty when there is an assignment of certain derivative contracts.

76 FR 66012 - Partner's Distributive Share

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27575
RIN	1545-BJ37
	REG-109564-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by January 23, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations removing § 1.704-1(b)(2)(iii)(e) (the de minimis partner rule) because the rule may have resulted in unintended tax consequences. The proposed regulations affect partnerships and their partners.

2011-10-24; vol. 76 # 205 - Monday, October 24, 2011

76 FR 65634 - Redetermination of the Consolidated Net Unrealized Built-In Gain and Loss

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27445
RIN	1545-BJ79
	REG-133002-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by January 23, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations under section 1502 of the Internal Revenue Code. The regulations will apply to corporations filing consolidated returns. The regulations will require a loss group or loss subgroup to redetermine its consolidated net unrealized built-in gain and loss in certain circumstances. This document also invites comments from the public regarding these proposed regulations.

2011-10-20; vol. 76 # 203 - Thursday, October 20, 2011

76 FR 65110 - Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27240
RIN	1545-BH49
TD	9548

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These final regulations are effective on October 20, 2011. Applicability Date: For dates of applicability, see § 1.355-2(i).

26 CFR Part 1

Summary

76 FR 65138 - Tax Return Preparer Penalties Under Section 6695; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-27183
RIN	1545-BK16
	REG-140280-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking and notice of public hearing.

26 CFR Part 1

Summary

This document contains a correction to a notice of proposed rulemaking and notice of public hearing (REG-140280-09) that would modify existing regulations related to the tax return preparer penalties under section 6695 of the Internal Revenue Code. The document was published in the Federal Register on Tuesday, October 11, 2011 (76 FR 62689).

2011-10-19; vol. 76 # 202 - Wednesday, October 19, 2011

76 FR 64816 - Deduction for Qualified Film and Television Production Costs

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-26973
RIN	1545-BJ24
TD	9552

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on October 18, 2011. Applicability Dates: For dates of applicability, see § 1.181-6T.

26 CFR Part 1

Summary

76 FR 64879 - Deduction for Qualified Film and Television Production Costs

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-26972
RIN	1545-BJ23
	REG-146297-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross reference to temporary regulation.

Written comments and requests for a public hearing must be received by January 17, 2012.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing temporary regulations relating to deductions for the costs of producing film and television productions. Those temporary regulations reflect changes to the law made by the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, and affect taxpayers that produce films and television productions within the United States. The text of those temporary regulations also serves as the text of these proposed regulations.

2011-10-13; vol. 76 # 198 - Thursday, October 13, 2011

76 FR 63574 - Tax Return Preparer Penalties Under Section 6695; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-26652
RIN	1545-BK16
	REG-140280-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking and notice of public hearing.

26 CFR Part 1

Summary

This document contains a correction to a notice of proposed rulemaking that were published in the Federal Register on Tuesday, October 11, 2011. These proposed regulations would modify existing regulations related to the tax return preparer penalties under section 6695 of the Internal Revenue Code. The proposed regulations are necessary to monitor and to improve compliance with the tax return preparer due to diligence requirements of this section.

2011-10-11; vol. 76 # 196 - Tuesday, October 11, 2011

76 FR 62689 - Tax Return Preparer Penalties Under Section 6695

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-26247
RIN	1545-BK16
	REG-140280-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by November 10, 2011. Outlines of topics to be discussed at the public hearing scheduled for November 7, 2011, must be received by November 1, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations that would modify existing regulations related to the tax return preparer penalties under section 6695 of the Internal Revenue Code (Code). These proposed regulations are necessary to monitor and to improve compliance with the tax return preparer due diligence requirements of section 6695(g). The proposed regulations affect tax return preparers. This document also provides notice of a public hearing on these proposed regulations.

2011-10-07; vol. 76 # 195 - Friday, October 7, 2011

76 FR 62327 - Retail Inventory Method

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-25946
RIN	1545-BJ64
	REG-125949-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronically generated comments and requests for a public hearing must be received by January 5, 2012.

26 CFR Part 1

Summary

This document contains proposed regulations relating to the retail inventory method of accounting. The regulations restate and clarify the computation of ending inventory values under the retail inventory method and provide a special rule for certain taxpayers that receive margin protection payments and similar vendor allowances. The regulations affect taxpayers that are retailers and elect to use a retail inventory method.

2011-10-06; vol. 76 # 194 - Thursday, October 6, 2011

76 FR 61946 - Implementation of Form 990; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-25773
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on October 6, 2011, and is applicable on September 8, 2011.

26 CFR Part 1

Summary

76 FR 61946 - Implementation of Form 990; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-25776
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on October 6, 2011, and is applicable on September 8, 2011.

26 CFR Parts 1 and 602

Summary

2011-09-30; vol. 76 # 190 - Friday, September 30, 2011

76 FR 60721 - Deduction for Qualified Film and Television Production Costs

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-24930
RIN	1545-BF94
TD	9551

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on September 29, 2011. Applicability Dates: For dates of applicability, see § 1.181-6.

26 CFR Parts 1 and 602

Summary

2011-09-16; vol. 76 # 180 - Friday, September 16, 2011

76 FR 57684 - Swap Exclusion for Section 1256 Contracts

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-23665
RIN	1545-BK22
	REG-111283-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by December 15, 2011. Outlines of topics to be discussed at the public hearing scheduled for January 19, 2012, must be received by December 14, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations that describe swaps and similar agreements that fall within the meaning of section 1256(b)(2)(B) of the Internal Revenue Code (Code). This document also contains proposed regulations that revise the definition of a notional principal contract under § 1.446-3 of the Income Tax Regulations. This document provides a notice of public hearing on these proposed regulations.

2011-09-15; vol. 76 # 179 - Thursday, September 15, 2011

76 FR 56973 - Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-23598
RIN	1545-BE77
TD	9542

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on September 15, 2011 and is applicable August 16, 2011.

26 CFR Part 1

Summary

2011-09-08; vol. 76 # 174 - Thursday, September 8, 2011

76 FR 55746 - Implementation of Form 990

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22614
RIN	1545-BH28
TD	9549

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on September 8, 2011. Applicability Date: For dates of applicability, see §§ 1.170A-9(k), 1.507-2(f), 1.509(a)-3(o), 1.6033-2(k), and 1.6043-3(e).

26 CFR Parts 1 and 602

Summary

2011-09-07; vol. 76 # 173 - Wednesday, September 7, 2011

76 FR 55255 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22738
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on September 7, 2011 and is applicable beginning October 18, 2011.

26 CFR Part 1

Summary

76 FR 55255 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22739
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective September 7, 2011 and is applicable beginning October 18, 2011.

26 CFR Part 1

Summary

76 FR 55321 - Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m); Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22734
RIN	1545-BI65
	REG-137125-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains a correction to a notice of proposed rulemaking (REG-137125-08) relating to the deduction limitation for certain employee remuneration in excess of $1,000,000 under the Internal Revenue Code. The document was published in the Federal Register on Friday, June 24, 2011 (76 FR 37034).

76 FR 55322 - Section 67 Limitations on Estates or Trusts

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22732
RIN	1545-BF80
	REG-128224-06

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Withdrawal of notice of proposed rulemaking; notice of proposed rulemaking and notice of public hearing.

Written and electronic comments must be received by December 6, 2011. Outlines of topics to be discussed at the public hearing scheduled for December 19, 2011 must be received by December 7, 2011.

26 CFR Part 1

Summary

This document withdraws the notice of proposed rulemaking that was published in the Federal Register on July 27, 2007, providing guidance on which costs incurred by estates or trusts other than grantor trusts (non-grantor trusts) are subject to the 2-percent floor for miscellaneous itemized deductions under section 67(a). This document contains proposed regulations that provide guidance on which costs incurred by estates or trusts other than grantor trusts (non-grantor trusts) are subject to the 2-percent floor for miscellaneous itemized deductions under section 67(a). The regulations affect estates and non-grantor trusts. This document also provides notice of a public hearing on these proposed regulations.

2011-09-01; vol. 76 # 170 - Thursday, September 1, 2011

76 FR 54409 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22523
RIN	1545-BK41
Docket No.	REG-126519-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

2011-08-30; vol. 76 # 168 - Tuesday, August 30, 2011

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22064
RIN	1545-BK25
TD	9535

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22066
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective August 30, 2011, and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

76 FR 53818 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22067
RIN	1545-BK41
	REG-126519-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

26 CFR Part 1

Summary

76 FR 53819 - Methods of Accounting Used by Corporations That Acquire the Assets of Other Corporations; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22051
RIN	1545-BD81
TD	9534

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on August 31, 2011.

26 CFR Part 1

Summary

76 FR 53819 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-22065
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 30, 2011 and is applicable beginning July 18, 2011.

26 CFR Part 1

Summary

2011-08-23; vol. 76 # 163 - Tuesday, August 23, 2011

76 FR 52556 - Election To Expense Certain Refineries

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21408
RIN	1545-BF05
TD	9547

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective August 22, 2011.

26 CFR Part 1 and 602

Summary

2011-08-19; vol. 76 # 161 - Friday, August 19, 2011

76 FR 51878 - Modifications of Certain Derivative Contracts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21179
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on August 19, 2011, and is applicable on July 22, 2011.

26 CFR Part 1

Summary

76 FR 51878 - Modifications of Certain Derivative Contracts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21180
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 19, 2011, and is applicable beginning July 22, 2011.

26 CFR Part 1

Summary

76 FR 51879 - Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21154
RIN	1545-BD04
TD	9546

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective August 19, 2011. Applicability Date: For dates of applicability, see § 1.142(a)(6)-1(i).

26 CFR Parts 1 and 17

Summary

76 FR 51922 - Modifications of Certain Derivative Contracts; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-21182
RIN	1545-BK13
	REG-109006-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG-109006-11) relating to whether an exchange for purposes of § 1.1001-1(a) occurs for the nonassigning counterparty when there is an assignment of certain derivative contracts. It was published in the Federal Register on Friday, July 22, 2011 (76 FR 43957).

2011-08-17; vol. 76 # 159 - Wednesday, August 17, 2011

76 FR 50887 - Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-20872
RIN	1545-BE77
TD	9542

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on August 16, 2011. Applicability Dates: For dates of applicability, see §§ 1.195-1(d), 1.248-1(f), and 1.709-1(b)(5).

26 CFR Part 1

Summary

76 FR 50931 - Health Insurance Premium Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-20728
RIN	1545-BJ82
	REG-131491-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written (including electronic) comments must be received by October 31, 2011. Outlines of topics to be discussed at the public hearing scheduled for November 17, 2011, at 10 a.m. must be received by November 10, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations relating to the health insurance premium tax credit enacted by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, as amended by the Medicare and Medicaid Extenders Act of 2010, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, and the Department of Defense and Full-Year Continuing Appropriations Act, 2011. These proposed regulations provide guidance to individuals who enroll in qualified health plans through Affordable Insurance Exchanges and claim the premium tax credit, and to Exchanges that make qualified health plans available to individuals and employers. This document also provides notice of a public hearing on these proposed regulations.

2011-08-10; vol. 76 # 154 - Wednesday, August 10, 2011

76 FR 49300 - Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-20224
RIN	1545-BF83
TD	9475

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on August 10, 2011 and is applicable on December 18, 2009.

26 CFR Part 1

Summary

76 FR 49570 - Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-19675
RIN	1545-BH67
TD	9540

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on August 10, 2011. Applicability Date: These regulations apply on August 10, 2011.

26 CFR Parts 1, 20, and 25

Summary

2011-08-01; vol. 76 # 147 - Monday, August 1, 2011

76 FR 45673 - Methods of Accounting Used by Corporations That Acquire the Assets of Other Corporations

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-19256
RIN	1545-BD81
TD	9534

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective date: These regulations are effective on August 31, 2011. Applicability date: For dates of applicability, see §§ 1.381(a)-1(e), 1.381(c)(4)-1(f), 1.381(c)(5)-1(f), and 1.446-1(e)(4)(iii).

26 CFR Part 1

Summary

2011-07-27; vol. 76 # 144 - Wednesday, July 27, 2011

76 FR 44800 - Election of Reduced Research Credit Under Section 280C(c)(3)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18993
RIN	1545-BI09
TD	9539

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

Effective Date: These regulations are effective on July 27, 2011. Applicability Date: For dates of applicability, see § 1.280C-4(c).

26 CFR Part 1

Summary

2011-07-22; vol. 76 # 141 - Friday, July 22, 2011

76 FR 43891 - Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18469
RIN	1545-BH56
TD	9530

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

This correction is effective on July 22, 2011, and is applicable beginning June 24, 2011.

26 CFR Part 1

Summary

76 FR 43892 - Modifications of Certain Derivative Contracts

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18529
RIN	1545-BK14
TD	9538

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on July 22, 2011. Applicability Date: For the date of applicability, see § 1.1001-4T(d).

26 CFR Part 1

Summary

76 FR 43957 - Modifications of Certain Derivative Contracts

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-18531
RIN	1545-BK13
	REG-109006-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

Written or electronic comments must be received by October 20, 2011. Outlines of topics to be discussed at the public hearing scheduled for Thursday, October 27, 2011, must be received by Thursday, October 20, 2011.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing temporary regulations relating to whether an exchange for purposes of § 1.1001-1(a) occurs for the nonassigning counterparty when there is an assignment of certain derivative contracts. The text of those regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.

2011-07-18; vol. 76 # 137 - Monday, July 18, 2011

76 FR 42036 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-17916
RIN	1545-BK40
TD	9536

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on July 18, 2011. Applicability Date: For dates of applicability, see § 1.901-2T(h)(3).

26 CFR Part 1

Summary

76 FR 42036 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-17920
RIN	1545-BK25
TD	9535

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on July 18, 2011. Applicability Date: For dates of applicability, see § 1.901-1(j) and § 1.901-2(h)(2).

26 CFR Part 1

Summary

76 FR 42076 - Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-17919
RIN	1545-BK41
	REG-126519-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Written or electronic comments and requests for a public hearing must be received by October 17, 2011.

26 CFR Part 1

Summary

In the Rules and Regulations section in this issue of the Federal Register , the IRS is issuing temporary regulations that provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.

2011-07-06; vol. 76 # 129 - Wednesday, July 6, 2011

76 FR 39278 - Modification of Treasury Regulations Pursuant to Section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-16856
RIN	1545-BK28
TD	9533

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

26 CFR Parts 1 and 48

Summary

76 FR 39341 - Encouraging New Markets Tax Credit Non-Real Estate Investments; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-16824
RIN	1545-BK21
	REG-114206-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to advance notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains a correction to advance notice of proposed rulemaking (REG-114206-11) that was published in the Federal Register on Tuesday, June 7, 2011 (76 FR 32880). This document invites comments from the public on how the new markets tax credit program may be amended to encourage non-real estate investments.

76 FR 39341 - Modification of Treasury Regulations Pursuant to Section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-16857
RIN	1545-BK27
	REG-118809-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Written and electronic comments and requests for a public hearing must be received by August 30, 2011.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the IRS is issuing final and temporary regulations that remove any reference to, or requirement of reliance on, credit ratings in regulations under the Internal Revenue Code (Code) and provide substitute standards of credit-worthiness where appropriate. The Dodd-Frank Wall Street Reform and Consumer Protection Act requires each Federal agency to take such actions regarding its regulations. These regulations affect persons subject to various provisions of the Code. The text of the temporary regulations published in the Rules and Regulations section of the Federal Register also serves as the text of the proposed regulations.

76 FR 39343 - New Markets Tax Credit Non-Real Estate Investments; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-16825
RIN	1545-BK04
	REG-101826-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains corrections to a notice of proposed rulemaking (REG-101826-11) that was published in the Federal Register on Tuesday, June 7, 2011 (76 FR 32882) modifying the new markets tax credit program to facilitate and encourage investments in non-real estate businesses in low-income communities.

2011-06-24; vol. 76 # 122 - Friday, June 24, 2011

76 FR 36993 - Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15741
RIN	1545-BH56
TD	9530

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

Effective Date: These regulations are effective on June 24, 2011. Applicability Date: For dates of applicability, see § 1.956-1(e)(6)(vii).

26 CFR Part 1

Summary

76 FR 36995 - Requirements for Taxpayers Filing Form 5472; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15943
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on June 24, 2011, and is applicable on June 10, 2011.

26 CFR Part 1

Summary

76 FR 36995 - Requirements for Taxpayers Filing Form 5472; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15946
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to temporary regulations.

This correction is effective on June 24, 2011, and is applicable on June 10, 2011.

26 CFR Part 1

Summary

76 FR 36996 - Extension of Time for Filing Returns

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15902
RIN	1545-BH88
TD	9531

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and removal temporary regulations

Effective Date: These regulations are effective on June 24, 2011. Applicability Date: For dates of applicability of these regulations, see §§ 1.6081-2(h), 1.6081-6(g), and 54.6081-1(f).

26 CFR Parts 1 and 54

Summary

76 FR 37034 - Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-15653
RIN	1545-BI65
	REG-137125-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments must be received by September 22, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations relating to the deduction limitation for certain employee remuneration in excess of $1,000,000 under the Internal Revenue Code (Code). The proposed regulations clarify that qualified performance-based compensation attributable to stock options and stock appreciation rights must specify the maximum number of shares with respect to which options or rights may be granted to each individual employee. The proposed regulations also clarify the application of the transition rule for taxpayers that are not publicly held corporations and then become publicly held corporations.

2011-06-10; vol. 76 # 112 - Friday, June 10, 2011

76 FR 33994 - Alternative Simplified Credit Under Section 41(c)(5)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-14407
RIN	1545-BH32
TD	9528

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective on June 9, 2011. Applicability Date: For dates of applicability, see §§ 1.41-6(j)(3), 1.41-8(b)(5), and 1.41-9(d).

26 CFR Part 1

Summary

76 FR 33997 - Requirements for Taxpayers Filing Form 5472

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Additional Documents

type	regulations.gov
FR Doc.	2011-14468
RIN	1545-BK01
TD	9529

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Temporary regulations.

Effective Date: These regulations are effective June 10, 2011. Applicability Dates: For dates of applicability, see §§ 1.6038A-1T(n) and 1.6038A-2(h).

26 CFR Part 1

Summary

76 FR 34017 - Claims for Credit or Refund

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Additional Documents

type	regulations.gov
FR Doc.	2011-14465
RIN	1545-BI36
	REG-137128-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by September 8, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations for filing a claim for credit or refund. The regulations provide guidance to taxpayers generally as to the proper place to file a claim for credit or refund. The regulations are updated to reflect changes made by the enactment of the Tax Reform Act of 1976, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Community Renewal Tax Relief Act of 2000. The regulations further are updated to reflect that the IRS may prescribe additional claim forms.

76 FR 34019 - Requirements for Taxpayers Filing Form 5472

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Additional Documents

type	regulations.gov
FR Doc.	2011-14469
RIN	1545-BK00
	REG-101352-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking by cross-reference to temporary regulations.

Written or electronic comments and requests for a public hearing must be received by September 8, 2011.

26 CFR Part 1

Summary

In the Rules and Regulations section of this issue of the Federal Register , the Treasury Department and the IRS are issuing temporary regulations that remove the duplicate filing requirement for Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.” Under this requirement, certain corporations that must file Form 5472 must also file a duplicate Form 5472 (including attachments and schedules) with the Internal Revenue Service Center in Philadelphia, PA. Because the IRS has determined that duplicate filing is no longer necessary, the requirement is being removed by the temporary regulations. The text of those temporary regulations also serves as the text of these proposed regulations.

2011-06-07; vol. 76 # 109 - Tuesday, June 7, 2011

76 FR 32880 - Encouraging New Markets Tax Credit Non-Real Estate Investments

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Additional Documents

type	regulations.gov
FR Doc.	2011-13981
RIN	1545-BK21
	REG-114206-11

DEPARTMENT OF TREASURY, Internal Revenue Service

Advance notice of proposed rulemaking.

Written and electronic comments must be submitted by September 6, 2011.

26 CFR Part 1

Summary

This document invites comments from the public on issues that the Treasury Department and the IRS may address in regulations relating to the new markets tax credit. Specifically, this document invites comments from the public on how the new markets tax credit program may be amended to encourage non-real estate investments. The regulations will affect taxpayers claiming the new markets tax credit. The Treasury Department and the IRS have published separately in this issue of the Federal Register , a notice of proposed rulemaking REG-101826-11 modifying the new markets tax credit program by providing specific rules concerning a qualified community development entity's investment of certain returns of capital from non-real estate businesses.

76 FR 32882 - New Markets Tax Credit Non-Real Estate Investments

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Additional Documents

type	regulations.gov
FR Doc.	2011-13978
RIN	1545-BK04
	REG-101826-11

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by September 8, 2011. Outlines of topics to be discussed at the public hearing scheduled for Thursday, September 29, 2011, must be received by September 8, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations modifying the new markets tax credit program to facilitate and encourage investments in non-real estate businesses in low-income communities. The regulations will affect taxpayers claiming the new markets tax credit and businesses in low-income communities relying on the program. This document also provides a notice of a public hearing on these proposed regulations. The Treasury Department and the IRS have published separately in this issue of the Federal Register an advance notice of proposed rulemaking REG-114206-11 requesting comments on additional modifications to the new markets tax credit program to facilitate and encourage investments in non-real estate businesses in low-income communities.

2011-06-01; vol. 76 # 105 - Wednesday, June 1, 2011

76 FR 31543 - Controlled Groups; Deferral of Losses; Hearing

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Additional Documents

type	regulations.gov
FR Doc.	2011-13407
RIN	1545-BI92
	REG-118761-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is being held on Wednesday, August 3, 2011, at 10 a.m. The IRS must receive outlines of the topics to be discussed at the hearing by Thursday, July 21, 2011.

26 CFR Part 1

Summary

This document provides notice of public hearing on a notice of proposed rulemaking providing guidance concerning the time for taking into account deferred losses on the sale or exchange of property between members of a controlled group.

2011-05-24; vol. 76 # 100 - Tuesday, May 24, 2011

76 FR 30052 - Controlled Groups; Deferral of Losses; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2011-12788
RIN	1545-BI92
	REG-118761-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking.

26 CFR Part 1

Summary

This document contains corrections to notice of proposed rulemaking (REG-118761-09) that was published in the Federal Register on Thursday, April 21, 2011 (76 FR 22336). The proposed regulations provide guidance concerning the time for taking into account deferred losses on the sale or exchange of property between members of a controlled group.

2011-05-19; vol. 76 # 97 - Thursday, May 19, 2011

76 FR 28890 - Treatment of Property Used To Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations

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Additional Documents

type	regulations.gov
FR Doc.	2011-12279
RIN	1545-BG96
TD	9526

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

Effective Date: These regulations are effective May 19, 2011. Applicability Dates: For dates of applicability, see §§ 1.367(a)-3(g)(1)(viii) and 1.367(b)-10(e).

26 CFR Part 1

Summary

2011-05-12; vol. 76 # 92 - Thursday, May 12, 2011

76 FR 27609 - Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction

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Additional Documents

type	regulations.gov
FR Doc.	2011-11580
RIN	1545-BG54
TD	9521

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final regulations.

This correction is effective on May 12, 2011, and is applicable on April 7, 2011.

26 CFR Part 1

Summary

2011-05-06; vol. 76 # 88 - Friday, May 6, 2011

76 FR 26178 - Modifications to Treatment of Aircraft and Vessel Leasing Income

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Additional Documents

type	regulations.gov
FR Doc.	2011-11164
RIN	1545-BG98
TD	9525

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

26 CFR Part 1

Summary

2011-04-21; vol. 76 # 77 - Thursday, April 21, 2011

76 FR 22336 - Controlled Groups; Deferral of Losses

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-9606
RIN	1545-BI92
	REG-118761-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written and electronic comments and requests for a public hearing must be received by July 20, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations that provide guidance concerning the time for taking into account deferred losses on the sale or exchange of property between members of a controlled group. These proposed regulations affect members of a controlled group and their shareholders.

2011-04-20; vol. 76 # 76 - Wednesday, April 20, 2011

76 FR 22064 - Guidance on Reporting Interest Paid to Nonresident Aliens; Hearing

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Additional Documents

type	regulations.gov
FR Doc.	2011-9609
RIN	1545-BJ01
	REG-146097-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is being rescheduled from Monday, April 25, 2011 to Wednesday, May 18, 2011, at 10 a.m.

26 CFR Parts 1 and 31

Summary

This document contains a rescheduled notice of public hearing on a notice of proposed rulemaking (REG-146097-09) that was published in the Federal Register on Friday, January 7, 2011 (76 FR 1105) providing guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals.

2011-04-13; vol. 76 # 71 - Wednesday, April 13, 2011

76 FR - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	C1-2011-4846
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

76 FR 20593 - Guidance Under Section 108(a) Concerning the Exclusion of Section 61(a)(12) Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity

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Additional Documents

type	regulations.gov
FR Doc.	2011-8758
RIN	1545-BJ14
	REG-154159-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking.

Written or electronic comments and requests for a public hearing must be received by July 12, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations relating to the exclusion from gross income under section 108(a) of discharge of indebtedness income of a grantor trust or an entity that is disregarded as an entity separate from its owner. The proposed regulations provide rules regarding the term “taxpayer” for purposes of applying section 108 to discharge of indebtedness income of a grantor trust or a disregarded entity. The proposed regulations affect grantor trusts, disregarded entities, and their owners.

76 FR 20595 - Guidance on Reporting Interest Paid to Nonresident Aliens; Hearing

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Additional Documents

type	regulations.gov
FR Doc.	2011-8771
RIN	1545-BJ01
	REG-146097-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is being rescheduled on Monday, April 25, 2011, at 10 a.m.

26 CFR Parts 1 and 31

Summary

This document contains a rescheduled notice of public hearing on a notice of proposed rulemaking (REG-146097-09) that was published in the Federal Register on Tuesday, January 18, 2011 (76 FR 2852) and Friday, January 7, 2011 (76 FR 1105) providing guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals.

2011-04-11; vol. 76 # 69 - Monday, April 11, 2011

76 FR 19907 - Clarification of Controlled Group Qualification Rules

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Additional Documents

type	regulations.gov
FR Doc.	2011-8555
RIN	1545-BG94
TD	9522

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: This regulation is effective on April 11, 2011. Applicability Date: For date of applicability, see § 1.1563-1(e).

26 CFR Part 1

Summary

2011-04-07; vol. 76 # 67 - Thursday, April 7, 2011

76 FR 19268 - Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d)

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-8229
RIN	1545-BG54
TD	9521

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations and removal of temporary regulations.

26 CFR Part 1

Summary

2011-03-31; vol. 76 # 62 - Thursday, March 31, 2011

76 FR 17781 - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-7506
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on March 31, 2011, and is applicable on March 4, 2011.

26 CFR Part 1

Summary

2011-03-30; vol. 76 # 61 - Wednesday, March 30, 2011

76 FR 17521 - Specified Tax Return Preparers Required To File Individual Income Tax Returns Using Magnetic Media

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Additional Documents

type	regulations.gov
FR Doc.	2011-7571
RIN	1545-BJ52
TD	9518

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulations.

26 CFR Parts 1 and 301

Summary

2011-03-22; vol. 76 # 55 - Tuesday, March 22, 2011

76 FR 15887 - Sales-Based Royalties and Vendor Allowances; Hearing

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Additional Documents

type	regulations.gov
FR Doc.	2011-6601
RIN	1545-BI57
	REG-149335-08

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of public hearing on proposed rulemaking.

The public hearing is being held on Wednesday, April 13, 2011, at 10 a.m. The IRS must receive outlines of the topics to be discussed at the hearing by Monday, March 28, 2011.

26 CFR Part 1

Summary

This document provides notice of public hearing on a notice of proposed rulemaking relating to the capitalization and allocation of royalties that are incurred only upon the sale of property produced or property acquired for resale (sales-based royalties) and adjusting the cost of merchandise inventory for an allowance, discount, or price rebated based on merchandise sales (sales-based vendor allowances). The regulations modify the simplified production method and the simplified resale method of allocating capitalized costs between ending inventory and cost of goods sold. The regulations affect taxpayers that incur capitalizable sales-based royalties and earn sales-based vendor allowances.

76 FR 15887 - Property Traded on an Established Market; Hearing Cancellation

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Additional Documents

type	regulations.gov
FR Doc.	2011-6603
RIN	1545-BJ71
	REG-131947-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Cancellation of notice of public hearing on proposed rulemaking.

The public hearing originally scheduled for April 13, 2011 at 10 a.m. is cancelled.

26 CFR Part 1

Summary

This document cancels a public hearing on a proposed rulemaking relating to determining when property is traded on an established market (that is, publicly traded) for purposes of determining the issue price of a debt instrument.

2011-03-04; vol. 76 # 43 - Friday, March 4, 2011

76 FR 11956 - Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock

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Additional Documents

type	regulations.gov
FR Doc.	2011-4846
RIN	1545-BH20
TD	9515

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final and temporary regulations.

26 CFR Part 1

Summary

2011-02-11; vol. 76 # 29 - Friday, February 11, 2011

76 FR 7757 - Guidance on Reporting Interest Paid to Nonresident Aliens; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2011-2922
RIN	1545-BJ01
	REG-146097-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to notice of proposed rulemaking; notice of a public hearing; and withdrawal of previously proposed rulemaking.

26 CFR Parts 1 and 31

Summary

This document contains corrections to notice of proposed rulemaking; notice of a public hearing; and withdrawal of previously proposed rulemaking (REG-146097-09) that was published in the Federal Register on Friday, January 7, 2011 (76 FR 1105). The proposed regulations 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.

2011-02-07; vol. 76 # 25 - Monday, February 7, 2011

76 FR 6553 - Time and Manner for Electing Capital Asset Treatment for Certain Self-Created Musical Works

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Additional Documents

type	regulations.gov
FR Doc.	2011-2549
RIN	1545-BG34
TD	9514

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation and removal of temporary regulation.

Effective Date: This regulation is effective on February 7, 2011. Applicability Date: For date of applicability, see § 1.1221-3(d).

26 CFR Part 1

Summary

2011-01-25; vol. 76 # 16 - Tuesday, January 25, 2011

76 FR - Hybrid Retirement Plans

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Additional Documents

type	regulations.gov
FR Doc.	C1-2010-25941
RIN	1545-BG36
TD	9505

DEPARTMENT OF THE TREASURY, Internal Revenue Service

26 CFR Part 1

Summary

76 FR 4244 - Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction

GPO FDSys XML | Text

Additional Documents

type	regulations.gov
FR Doc.	2011-1408
RIN	1545-BF85
TD	9391

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on January 25, 2011, and is applicable on April 9, 2008.

26 CFR Part 1

Summary

2011-01-21; vol. 76 # 14 - Friday, January 21, 2011

76 FR 3837 - Nuclear Decommissioning Funds; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2011-1215
RIN	1545-BF08
TD	9512

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correcting amendment.

This correction is effective on January 21, 2011, and is applicable on December 23, 2010.

26 CFR Part 1

Summary

2011-01-18; vol. 76 # 11 - Tuesday, January 18, 2011

76 FR 2852 - Guidance on Reporting Interest Paid to Nonresident Aliens; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2011-829
RIN	1545-BJ01
	REG-146097-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to a notice of proposed rulemaking and notice of public hearing.

26 CFR Parts 1 and 31

Summary

This document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG-146097-09) that was published in the Federal Register on Friday, January 7, 2011 (76 FR 1105) providing guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals.

2011-01-07; vol. 76 # 5 - Friday, January 7, 2011

76 FR 1063 - Modifications of Debt Instruments

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Additional Documents

type	regulations.gov
FR Doc.	2011-86
RIN	1545-BJ30
TD	9513

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Final regulation.

Effective Date: These regulations are effective on January 7, 2011. Applicability Date: For dates of applicability, see § 1.1001-3(h).

26 CFR Part 1

Summary

76 FR 1101 - Property Traded on an Established Market

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Additional Documents

type	regulations.gov
FR Doc.	2011-83
RIN	1545-BJ71
	REG-131947-10

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking and notice of public hearing.

Written or electronic comments must be received by March 8, 2011. Outlines of topics to be discussed at the public hearing scheduled for April 13, 2011, at 10 a.m. must be received by March 4, 2011.

26 CFR Part 1

Summary

This document contains proposed regulations relating to determining when property is traded on an established market (that is, publicly traded) for purposes of determining the issue price of a debt instrument. The regulations amend the current regulations to clarify the circumstances that cause property to be publicly traded. The regulations provide needed guidance to issuers and holders of debt instruments. This document also provides a notice of a public hearing on these proposed regulations.

76 FR 1105 - Guidance on Reporting Interest Paid to Nonresident Aliens

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Additional Documents

type	regulations.gov
FR Doc.	2011-82
RIN	1545-BJ01
	REG-146097-09

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Notice of proposed rulemaking; notice of public hearing; and withdrawal of previously proposed rulemaking.

Written or electronic comments must be received by April 7, 2011. Outlines of topics to be discussed at the public hearing scheduled for April 28, 2011, at 10 a.m. must be received by April 8, 2011. The proposed rule published on August 2, 2002 is withdrawn as of January 7, 2011.

26 CFR Parts 1 and 31

Summary

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. 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 published on August 2, 2002 (67 FR 50386).

2011-01-06; vol. 76 # 4 - Thursday, January 6, 2011

76 FR 708 - Electronic Funds Transfer of Depository Taxes; Correction

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Additional Documents

type	regulations.gov
FR Doc.	2010-33357
RIN	1545-BJ13
TD	9507

DEPARTMENT OF THE TREASURY, Internal Revenue Service

Correction to final and temporary regulations.

Effective January 6, 2011.

26 CFR Parts 1, 31, 40, and 301

Summary

26 CFR 1.707-1 - Transactions between partner and partnership.

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