Home » Rulemaking » Unified Rule for Loss on Subsidiary Stock

Unified Rule for Loss on Subsidiary Stock

Document ID: IRS-2007-0020-0001
Document Type: Proposed Rule
Agency: Internal Revenue Service
Topics: Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number: 07-00187
CFR Citation: 26 CFR 1
View Document:

Details Information

Received Date:	January 23 2007, at 07:07 AM Eastern Standard Time
Start-End Page:	2963 - 3020
Comment Start Date:	January 23 2007, at 12:00 AM Eastern Standard Time
Comment Due Date:	April 23 2007, at 11:59 PM Eastern Standard Time

Comments

Total: 2

Comment on FR Doc # 07-00187
Submitter: Smith, Patrick Posted: 10/02/2007 ID: IRS-2007-0020-0002

Comment Period Closed
Apr 23,2007 11:59 PM ET

Unified Rule for Loss on Subsidiary Stock
Submitter: Silverman, Mark Posted: 07/25/2008 ID: IRS-2007-0020-0007

Comment Period Closed
Apr 23,2007 11:59 PM ET

Related Documents

Total: 489

Basis Reporting by Securities Brokers and Basis Determination for Stock

Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans

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

Damages Received on Account of Personal Physical Injuries or Physical Sickness; Hearing

Guidance Regarding Foreign Base Company Sales Income

Consolidated Returns; Intercompany Obligations

Guidance Regarding Foreign Base Company Sales Income

Creditor Continuity of Interest; Correction

Conduit Financing Arrangements

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

Creditor Continuity of Interest

Information Reporting for Discharges of Indebtedness; Correction

Further Guidance on the Application of Section 409A to Nonqualified Deferred Compensation Plans

Determining the Amount of Taxes Paid for Purposes of Section 901; Hearing Cancellation

Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions; Hearing

Section 1367 Regarding Open Account Debt; Correction

Employee Stock Purchase Plans Under Internal Revenue Code Section 423; Hearing

Section 108 Reduction of Tax Attributes for S Corporations; Hearing Cancellation

Alcohol Fuel and Biodiesel; Renewable Diesel; Alternative Fuel; Diesel-Water Fuel Emulsion; Taxable Fuel Definitions; Excise Tax Returns; Hearing

Determining the Amount of Taxes Paid for Purposes of Section 901; Correction

Section 1367 Regarding Open Account Debt; Correction

Information Reporting for Discharges of Indebtedness

Information Reporting on Employer-Owned Life Insurance Contracts

Election To Expense Certain Refineries; Hearing Cancellation

Infrastructure Improvements Under Section 897

Section 108(e)(8) Application to Partnerships

Extension of Time for Filing Returns; Hearing

Treatment of Payments in Lieu of Taxes Under Section 141

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Unified Rule for Loss on Subsidiary Stock; Correction

Section 1367 Regarding Open Account Debt

Unified Rule for Loss on Subsidiary Stock; Correction

Information Reporting Requirements Under Internal Revenue Code Section 6039; Hearing

Income, Excise, and Estate and Gift Taxes; Effective Dates and Other Issues Arising Under the Employee Benefit Provisions of the Tax Reform Act of 1984; Correction

Notice to Participants of Consequences of Failing To Defer Receipt of Qualified Retirement Plan Distributions; Expansion of Applicable Election Period and Period for Notices

Regulations Enabling Elections for Certain Transactions under Section 336(e); Correction

Public Approval Guidance for Tax-Exempt Bonds; Correction

Capital Costs Incurred To Comply With EPA Sulfur Regulations; Hearing Cancellation

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Regulations Enabling Elections for Certain Transactions Under Section 336(e); Correction

Amendments to Section 7216 Regulations--Disclosure or Use of Information by Preparers of Returns; Hearing Cancellation

Guidance Under Sections 642 and 643 (Income Ordering Rules); Hearing

Declaratory Judgments--Gift Tax Determinations; Hearing Cancellation

Transfers by Domestic Corporations That Are Subject to Section 367(a)(5); Distributions by Domestic Corporations That Are Subject to Section 1248(f); Correction

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Targeted Populations Under Section 45D(e)(2)

Unified Rule for Loss on Subsidiary Stock

Implementation of Form 990

Public Approval Guidance for Tax-Exempt Bonds

Farmer and Fisherman Income Averaging; Correction

Regulations Enabling Elections for Certain Transactions Under Section 336(e)

Transfers by Domestic Corporations That Are Subject to Section 367(a)(5); Distributions by Domestic Corporations That Are Subject to Section 1248(f)

Information Reporting Requirements Under Internal Revenue Code Section 6039; Correction

Amendments to New Markets Tax Credit Regulations

Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions

Section 108 Reduction of Tax Attributes for S Corporations

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders)

Rules for Home Construction Contracts

Mortality Tables for Determining Present Value

Converting an IRA Annuity to a Roth IRA

Section 42 Utility Allowance Regulations Update

Employee Stock Purchase Plans Under Internal Revenue Code Section 423

Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income; Correction

Dependent Child of Divorced or Separated Parents or Parents Who Live Apart; Correction

Farmer and Fisherman Income Averaging

Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction

Information Reporting Requirements Under Internal Revenue Code Section 6039

Determining the Amount of Taxes Paid for Purposes of Section 901

Guidance Under Sections 642 and 643 (Income Ordering Rules); Correction

Determining the Amount of Taxes Paid for Purposes of Section 901

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders)

Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

Reasonable Good Faith Interpretation of Required Minimum Distribution Rules by Governmental Plans

Election to Expense Certain Refineries

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

Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses

Modifications to Subpart F Treatment of Aircraft and Vessel Leasing Income

Multiemployer Plan Funding Guidance; Correction

Dependent Child of Divorced or Separated Parents or Parents Who Live Apart

Extension of Time for Filing Returns

Multiemployer Plan Funding Guidance; Hearing

Capital Costs Incurred To Comply With EPA Sulfur Regulations

Guidance Under Section 956 for Determining the Basis of Property Acquired in Certain Nonrecognition Transactions

Guidance Under Sections 642 and 643 (Income Ordering Rules)

Accrual Rules for Defined Benefit Plans

Alternative Simplified Credit Under Section 41(c)(5)

Alternative Simplified Credit under Section 41(c)(5)

Partners Distributive Share; Correction

Qualified Nonpersonal Use Vehicles

Guidance Regarding Foreign Base Company Sales Income; Hearing

Treatment of Property Used To Acquire Parent Stock in Certain Triangular Reorganizations Involving Foreign Corporations

Guidance Under Section 7874 for Determining the Ownership Percentage in the Case of Expanded Affiliated Groups

Partners Distributive Share

Contributed Property

Assumption of Liabilities

Corporate Reorganizations; Amendment to Transfers of Assets or Stock Following a Reorganization

Hybrid Retirement Plans; Hearing

Guidance Regarding Foreign Base Company Sales Income; Correction

Standards for Recognition of Tax-Exempt Status if Private Benefit Exists or if an Applicable Tax-Exempt Organization Has Engaged in Excess Benefit Transaction(s); Correction

Hybrid Retirement Plans; Correction

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable

Measurement of Assets and Liabilities for Pension Funding Purposes; Hearing

Nuclear Decommissioning Funds; Hearing

Income Taxes: Hybrid Retirement Plans; Correction

Guidance Regarding Deduction and Capitalization ofExpenditures Related to Tangible Property; Correction

Guidance Regarding Foreign Base Company Sales Income; Correction

Amendment of Matching Rule for Certain Gains on Member Stock; Guidance; Correction

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction

Multiemployer Plan Funding Guidance; Correction

Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts; Hearing

Application of Normalization Accounting Rules to Balances of Excess Deferred Income Taxes and Accumulated Deferred Investment Tax Credits of Public Utilities Whose Assets Cease To Be Public Utility Property; Correction

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

Automatic Contribution Arrangements; Hearing

TIPRA Amendments to Section 199; Correction

Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Hearing Cancellation

Treatment of Overall Foreign and Domestic Losses; Hearing

Abandonment of Stock or Other Securities; Correction

Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction

Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts; Correction

Application of Section 338 to Insurance Companies; Correction

Dependent Child of Divorced or Separated Parents or Parents Who Live Apart; Hearing

Multiemployer Plan Funding Guidance

Abandonment of Stock or Other Securities

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Diversification Requirements for Variable Annuity, Endowment, and Life Insurance Contracts

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

Qualified Films Under Section 199

Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts

Modifications of Commercial Mortgage Loans Held by a Real Estate Mortgage Investment Conduit (REMIC); Hearing

Guidance Regarding Foreign Base Company Sales Income

Consolidated Returns; Intercompany Obligations

Consolidated Returns; Intercompany Obligations; Hearing

TIPRA Amendments to Section 199

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

Time and Mannerfor Electing Capital Asset Treatment for Certain Self-Created Musical Works

Calculating and Apportioning the Section 11(b)(1) Additional Tax Under Section 1561 for Controlled Groups; Correction

Consolidated Returns; Intercompany Obligations; Hearing

Guidance on Qualified Tuition Programs Under Section 529

Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d); Correction

Guidance Under Section 1502; Miscellaneous Operating Rules for Successor Persons; Succession to Items of the Liquidating Corporation

Clarification to Section 6411 Regulations; Hearing

S Corporation Guidance Under AJCA of 2004 and GOZA of 2005; Hearing Cancellation

Diversification Requirements for Certain Defined Contribution Plans

Measurement of Assets and Liabilities for Pension Funding Purposes

Nuclear Decommissioning Funds

Hybrid Retirement Plans

Calculating and Apportioning the Section 11(b)(1) Additional Tax Under Section 1561 for Controlled Groups

Calculating and Apportioning the Section 11(b)(1) Additional Tax under Section 1561 for Controlled Groups.

Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d)

Treatment of Overall Foreign and Domestic Losses

Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d)

Benefit Restrictions for Underfunded Pension Plans; Hearing

Foreign Tax Credit: Notification of Foreign Tax Redeterminations; Correction

Notification Requirement for Tax-Exempt Entities Not Currently Required To File; Correction

Returns Required on Magnetic Media; Correction

Update and Revision of Sections 1.381(c)(4)-1 and 1.381(c)(5)-1; Correction

Partners Distributive Share; Hearing

Information Reporting for Lump-Sum Timber Sales

Notification Requirement for Tax-Exempt Entities Not Currently Required to File; Correction

Update and Revision of Sections 1.381(c)(4)-1 and 1.381(c)(5)-1

Benefit Restrictions for Underfunded Pension Plans

Notification Requirement for Tax-Exempt Entities Not Currently Required To File

Notification Requirement for Tax-Exempt Entities Not Currently Required to File

Information Reporting on Employer-Owned Life Insurance Contracts

Modifications of Commercial Mortgage Loans Held by a Real Estate Mortgage Investment Conduit (REMIC)

Benefit Restrictions for Underfunded Pension Plans; Correction

Withholding Procedure Under Section 1441 for Certain Distributions to Which Section 302 Applies; Correction

Automatic Contribution Arrangements

Partners Distributive Share; Correction

Consolidated Returns; Intercompany Obligations; Correction

Corporate Reorganizations; Transfers of Assets or Stock Following a Reorganization

Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

Withholding Procedures Under Section 1441 for Certain Distributions to Which Section 302 Applies

Compensation for Labor or Personal Services: Artists and Athletes

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction

Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

Section 1045 Application to Partnerships; Correction

Exclusions From Gross Income of Foreign Corporations; Hearing Cancellation

Clarification of Section 6411 Regulations; Correcting Amendment

Consolidated Returns; Intercompany Obligations

Income taxes: Employee benefits; cafeteria plans

Arbitrage Guidance for Tax-Exempt Bonds

Medical and Accident Insurance Benefits Under Qualified Plans; Correction

Corporate Estimated Tax; Correction

Revised Regulations Concerning Section 403(b) Tax-Sheltered Annuity Contracts; Correction

Employee Benefits--Cafeteria Plans; Correction

Employee Benefits--Cafeteria Plans; Hearing

Section 67 Limitations on Estates or Trusts; Hearing

Qualified Films Under Section 199; Correction

Corporate Estimated Tax; Correction

Corporate Estimated Tax; Correcting Amendment

Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction

Employer Comparable Contributions to Health Savings Accounts Under Section 4980G; Hearing Cancellation

Information Returns Required With Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic Corporations; Correction

Treatment of Certain Nuclear Decommissioning Funds for Purposes of Allocating Purchase Price in Certain Deemed and Actual Asset Acquisitions

Benefit Restrictions for Underfunded Pension Plans

Clarification of Section 6411 Regulations

Clarification to Section 6411 Regulations

Income taxes: Employee benefits; cafeteria plans; removed

Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated; Correction

Section 67 Limitations on Estates or Trusts; Correction

Medical and Accident Insurance Benefits Under Qualified Plans

Disclosure Requirements With Respect to Prohibited Tax Shelter Transactions; Correction

Exclusions From Gross Income of Foreign Corporations; Correction

Employee Benefits--Cafeteria Plans

Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated

Employee Benefits--Cafeteria Plans

Built-in Gains and Losses Under Section 382(h); Correction

Diversification Requirements for Variable Annuity, Endowment, and Life Insurance Contracts

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Section 1248 Attribution Principles

Return Required by Subchapter T Cooperatives Under Section 6012

Abandonment of Stock and Other Securities

Section 67 Limitations on Estates or Trusts

Mortality Tables for Determining Present Value

Agent for a Consolidated Group With Foreign Common Parent

Section 1367 Regarding Open Account Debt; Correction

Guidance Under Section 1502; Amendment of Tacking Rule Requirements of Life-Nonlife Consolidated Regulations

Qualified Films Under Section 199; Correction

Mortality Tables for Determining Present Value; Correction

Treatment of Excess Loss Accounts

Income taxes: Business electronic filing and burden reduction; facilitation

Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions

Information Returns Required with Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic Corporations

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Guidance under Subpart F Relating to Partnerships

Deductions for Entertainment Use of Business Aircraft; Correction

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable; Hearing

Guidance Necessary to Facilitate Business Electronic Filing and Burden Reduction; Correction

Exclusions from Gross Income of Foreign Corporations

Section 42 Qualified Contract Provisions

Section 42 Utility Allowance Regulations Update

Guidance Regarding the Active Trade or Business Requirement under Section 355(b)

Deemed IRAs in Governmental Plans/Qualified Nonbank Trustee Rules

Unified Rule for Loss on Subsidiary Stock

Deductions for Entertainment Use of Business Aircraft

Built-in Gains and Losses Under Section 382(h)

Unified Rule for Loss on Subsidiary Stock; Correction

Qualified Films Under Section 199

Guidance Regarding the Active Trade or Business Requirement Under Section 355(b); Correction

Designated Roth Accounts Under Section 402A; Correction

Mortality Tables for Determining Present Value

Limitations on Benefits and Contributions Under Qualified Plans; Correction

Distributions From a Pension Plan Upon Attainment of Normal Retirement Age

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments; Correction

Income taxes: Open account debt between S corporations and their shareholders; hearing

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments; Correction

Determining the Amount of Taxes Paid for Purposes of Section 901; Correction

Section 1367 Regarding Open Account Debt; Correction

Guidance Regarding the Active Trade or Business Requirement Under Section 355(b)

Dependent Child of Divorced or Separated Parents or Parents Who Live Apart

Anti-Avoidance and Anti-Loss Reimportation Rules Applicable Following a Loss on Disposition of Stock of Consolidated Subsidiaries; Correction

Dual Consolidated Loss Regulations; Correction

Application of Section 409A to Nonqualified Deferred Compensation Plans

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments

Section 1367 Regarding Open Account Debt

Anti-Avoidance and Anti-Loss Reimportation Rules Applicable Following a Loss on Disposition of Stock of Consolidated Subsidiaries

United States Dollar Approximate Separate Transactions Method

Determining the Amount of Taxes Paid for Purposes of Section 901

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction

Guidance Regarding the Simplified Service Cost Method and the Simplified Production Method

Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

Computer Software Under Section 199(c)(5)(B)

Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction; Correction

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Depreciation of MACRS Property That Is Acquired in a Like-Kind Exchange or as a Result of an Involuntary Conversion

Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Section 181--Deduction for Qualified Film and Television Production Costs

Updated Mortality Tables for Determining Current Liability

Guidance Necessary To Facilitate Business Electronic Filing; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Guidance Necessary to Facilitate Business Electronic Filing Under Section 1561

Income taxes: Space and ocean activities and communications; source of income; correction

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B); Correction Notice

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Qualified Amended Returns

Income Attributable to Domestic Production Activities; Correction

Reporting Rules for Widely Held Fixed Investment Trusts

Changes in Computing Depreciation

Exchanges of Property for an Annuity

Income and Currency Gain or Loss With Respect to a Section 987 QBU; Correction

Railroad Track Maintenance Credit; Hearing Cancellation

General Allocation and Accounting Regulations Under Section 141

Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; Stewardship Expense; Correction

Guidance Necessary To Facilitate Business Electronic Filing Under Section 1561

Treatment of Services Under Section 482 Allocation of Income and Deductions From Intangibles Stewardship Expense; Correction

Prohibited Allocations of Securities in an S Corporation

Residence Rules Involving U.S. Possessions; Correction

Corporate Reorganizations; Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B)

Income taxes: Credit for increasing research activities

Income taxes: Income attributable to domestic production activities; deduction

Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals

Exclusion From Gross Income of Previously Taxed Earnings and Profits and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property; Correction

Exhanges of Property for an Annuity

Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

Partners Distributive Share: Foreign Tax Expenditures; Correction

TIPRA Amendments to Section 199; Correction

Credit for Increasing Research Activities; Correction

General Allocation and Accounting Regulations Under Section 141; Correction

Income and Currency Gain or Loss With Respect to a Section 987 QBU; Hearing Cancellation

Residence Rules Involving U.S. Possessions

Credit for Increasing Research Activities

Definition of Taxpayer for Purposes of Section 901 and Related Matters; Correction

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Hearing Cancellation

Limitations on Transfers of Built-in Losses

Attained Age of the Insured Under Section 7702; Correction

Treatment of Payments in Lieu of Taxes Under Section 141

TIPRA Amendments to Section 199

Partners Distributive Share: Foreign Tax Expenditures

Exchanges of Property for an Annuity

Stock Transfer Rules: Carryover of Earnings and Taxes; Correction

Determination of Interest Expense Deduction of Foreign Corporations; Correction

General Allocation and Accounting Regulations Under Section 141

Section 411(d)(6) Protected Benefits; Correction

Elimination of Country-by-Country Reporting to Shareholders of Foreign Taxes Paid by Regulated Investment Companies

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Correction

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments; Hearing Cancellation

Attained Age of the Insured Under Section 7702

Definition of Essential Governmental Function Under Section 7871 and Limitation to Activities Customarily Performed by States and Local Governments; Correction

Railroad Track Maintenance Credit

Income and Currency Gain or Loss With Respect to a Section 987 QBU

Special Depreciation Allowance

Dividends Paid Deduction for Stock Held in Employee Stock Ownership Plan

Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property

Computer Software Under Section 199(c)(5)(B); Hearing Cancellation

REMIC Residual Interests-Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders); Correction

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable

Income Attributable to Domestic Production Activities; Correction Notice

Effect of Election on Corporation

Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations; Correction

Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correcting Amendment

Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property

Determination of Interest Expense Deduction of Foreign Corporations

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents; Correction Notice

Reporting of Gross Proceeds Payments to Attorneys; Correction

Section 1248 Attribution Principles; Correction

Revisions to Regulations Relating to Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments; Hearing

Section 411(d)(6) Protected Benefits

Income taxes: Stock transfer rules; carryover of tax attributes

Section 1221(a)(4) Capital Asset Exclusion for Accounts and Notes Receivable

Definition of Taxpayer for Purposes of Section 901 and Related Matters

Reporting Rules for Widely Held Fixed Investment Trusts

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions) (Foreign Holders)

REMIC Residual Interests--Accounting for REMIC Net Income (Including Any Excess Inclusions (Foreign Holders)

Computer Software Under Section 199 (c)(5)(B); Hearing

Exclusion of Employees of 501(c)(3) Organizations in 401(k) and 401(m) Plans

Designated Roth Accounts Under Section 402A; Hearing

Reporting of Gross Proceeds Payments to Attorneys

United States Dollar Approximate Separate Transactions Method

Computer Software Under Section 199(c)(5)(B); Correction

Expenses for Household and Dependent Care Services Necessary for Gainful Employment; Correction

Corporate Distributions and Adjustments

Effect of Elections in Certain Multi-Step Transactions

Computer Software Under Section 199(c)(5)(B); Correction

Distributions of Interests in a Loss Corporation From Qualified Trusts

Information Returns Required With Respect to Certain Foreign Corporations and Certain Foreign-Owned Domestic Corporations

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction; Correction

Revisions to Regulations Relating To Repeal of Tax on Interest of Nonresident Alien Individuals and Foreign Corporations Received From Certain Portfolio Debt Investments

Designated Roth Accounts Under Section 402A; Hearing

Guidance Under Section 1502; Suspension of Losses on Certain Stock Dispositions; Correction

Guidance Under Section 7874 Regarding Expatriated Entities and Their Foreign Parents

Section 1248 Attribution Principles

Computer Software Under Section 199(c)(5)(B)

Guidance Necessary To Facilitate Business Electronic Filing and Burden Reduction

Revision of Income Tax Regulations Under Sections 367, 884, and 6038B Dealing With Statutory Mergers or Consolidations Under Section 368(a)(1)(A) Involving One or More Foreign Corporations, and Guidance Necessary To Facilitate Business Electronic Filing Under Section 6038B; Correction

Income taxes: Insurance companies; sale or acquisition of assets under section 338

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit; Correcting Amendment

Application of Section 338 to Insurance Companies; Correction

Withdrawal of Proposed Regulations Regarding Intercompany Transactions; Manufacturer Incentive Payments

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit; Correction

Intercompany Transactions; Manufacturer Incentive Payments

Revisions to Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Revisions of Information Reporting Regulations; Correction

Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations; Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations

Statutory Mergers and Consolidations

Guidance Under Section 1502; Amendment of Tacking Rule Requirements of Life-Nonlife Consolidated Regulations

Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities; Hearing Cancellation

Withdrawal of Proposed Regulations Relating to Redemptions Taxable as Dividends

Time for Filing Employment Tax Returns and Modifications to the Deposit Rules; Hearing Cancellation

Updated Mortality Tables for Determining Current Liability; Hearing Cancellation

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Time and Manner of Making Section 163(d)(4)(B) Election To Treat Qualified Dividend Income as Investment Income; Correction

Application of Section 338 to Insurance Companies

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit

Treatment of Excess Loss Accounts; Correction

Corporate Estimated Tax; Correction

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts; Correction

Time for Filing Employment Tax Returns and Modifications to the Deposit Rules; Correction

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Hearing Cancellation

Agent for a Consolidated Group With Foreign Common Parent

Income Taxes

Definition of Contribution in Aid of Construction Under Section 118(c)

[Federal Register: March 7, 2006 (Volume 71, Number 44)]

Corporate Estimated Tax

Special Rules Regarding Certain Section 951 Pro Rata Share Allocations

Application of Section 367 in Cross Border Section 304 Transactions; Certain Transfers of Stock Involving Foreign Corporations

Partners Distributive Share; Hearing Cancellation

Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property

Allocation and Apportionment of Expenses Alternative Method for Determining Tax Book Value of Assets

Designated Roth Accounts Under Section 402A

Statutory Mergers and Consolidations

Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions; Treatment of Excess Loss Accounts

Treatment of Excess Loss Accounts

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction

Guidance Under Subpart F Relating to Partnerships

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Obligations of States and Political Subdivisions; Correction

Guidance Under Section 7874 for Determining Ownership by Former Shareholders or Partners of Domestic Entities

[Federal Register: December 27, 2005 (Volume 70, Number 247)]

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Section 1374 Effective Dates

Application of Section 409A to Nonqualified Deferred Compensation Plans; Correction

Obligations of States and Political Subdivisions

Source of Income From Certain Space and Ocean Activities; Source of Communications Income; Hearing Cancellation

Guidance on Passive Foreign Investment Company (PFIC) Purging Elections

Information Reporting Relating to Taxable Stock Transactions

Updated Mortality Tables for Determining Current Liability

Partners Distributive Share

Guidance Under Section 951 for Determining Pro Rata Share; Correction

Low-Income Housing Credit Allocation and Certification; Revisions

Income Attributable to Domestic Production Activities

Corporate Reorganizations; Guidance on the Measurement of Continuity of Interest

Source of Income From Certain Space and Ocean Activities; Source of Communications Income; Correction

Application of Section 409A to Nonqualified Deferred Compensation Plans

Stock Held by Foreign Insurance Companies

Partnership Equity for Services; Hearing Cancellation

Section 411(d)(6) Protected Benefits; Correction

Source of Income From Certain Space and Ocean Activities; Source of Communications Income

Special Rule Regarding Certain Section 951 Pro Rata Share Allocations

Converting an IRA Annuity to a Roth IRA

Section 411(d)(6) Protected Benefits

Guidance Regarding the Simplified Service Cost Method and the Simplified Production Method

Return Required by Subchapter T Cooperatives Under Section 6012

Credit for Increasing Research Activities