eLaws
|
eCases
|
United States Code
|
Federal Courts
|
Sign In
Sign Up
eLaws
eCases »
United States Code
Federal Courts »
Home
»
Rulemaking
» Swap Exclusion for Section 1256 Contracts
Swap Exclusion for Section 1256 Contracts
Document ID:
IRS-2011-0029-0001
Document Type:
Proposed Rule
Agency:
Internal Revenue Service
Topics:
Income Taxes, Reporting and Recordkeeping Requirements
Federal Register Number:
2011-23665
CFR Citation:
26 CFR Part 1
View Document:
Details Information
Document Subtype:
Notice of Proposed Rulemaking (NPRM)
Received Date:
September 16 2011, at 12:00 AM Eastern Daylight Time
Start-End Page:
57684 - 57690
Comment Start Date:
September 16 2011, at 12:00 AM Eastern Standard Time
Comment Due Date:
December 15 2011, at 11:59 PM Eastern Standard Time
Comments
View All
Total:
13
Comment on FR Doc # 2011-23665
Submitter:
Bloomfield, Micah
Posted:
09/27/2011
ID:
IRS-2011-0029-0002
Comment Period Closed
Dec 15,2011 11:59 PM ET
Comment on FR Doc # 2011-23665
Submitter:
Bautz, Peter
Posted:
12/15/2011
ID:
IRS-2011-0029-0004
Comment Period Closed
Dec 15,2011 11:59 PM ET
Comment on FR Doc # 2011-23665
Submitter:
Desai, Pinank
Posted:
12/15/2011
ID:
IRS-2011-0029-0005
Comment Period Closed
Dec 15,2011 11:59 PM ET
Comment on FR Doc # 2011-23665
Submitter:
Wierzynski, Barbara
Posted:
12/16/2011
ID:
IRS-2011-0029-0006
Comment Period Closed
Dec 15,2011 11:59 PM ET
Swap Exclusion for Section 1256 Contracts
Submitter:
Baker, Richard
Posted:
12/20/2011
ID:
IRS-2011-0029-0008
Comment Period Closed
Dec 15,2011 11:59 PM ET
Related Documents
More
Total:
304
Information Reporting for Affordable Insurance Exchanges
Noncompensatory Partnership Options: Correction
Regulations Enabling Elections for Certain Transactions under Section 336(e)
Computation of, and Rules Relating to, Medical Loss Ratio
Health Insurance Premium Tax Credit: Minimum Value of Eligible Employer-Sponsored Plans and Other Rules
Outbound Property Transfers by Domestic Corporations: Certain Stock Distributions; Correction
Reporting for Premium
500,000 Dollar Deduction Limitation for Remuneration Provided by Certain Health Insurance Providers
Noncompensatory Partnership Options
Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage
Section 482: Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; CFR Correction
Unified Rule for Loss on Subsidiary Stock; CFR Correction
Treatment of Overall Foreign and Domestic Losses; CFR Correction
Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangible Property; Stewardship Expense; CFR Correction
Unified Rule for Loss on Subsidiary Stock; CFR Correction
Noncompensatory Partnership Options; Correction
Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage; Correction
Indirect Stock Transfers and Coordination Rule Exceptions: Transfers of Stock or Securities in Outbound Asset Reorganizations
Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income
Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated; Correction
Noncompensatory Partnership Options
Treatment of Grantor of Option on Partnership Interest
Health Insurance Premium Tax Credit
Net Investment Income Tax; Correction
Shared Responsibility Payment for Not Maintaining Minimum Essential Coverage
Failure To File Gain Recognition Agreements and Other Required Filings
Rules Relating to Additional Medicare Tax; Correction
Rules Relating to Additional Medicare Tax; Correction
Partners Distributive Share; Correction
Disclosure or Use of Information by Preparers of Returns; Correction
Treasury Inflation-Protected Securities Issued at a Premium; Bond Premium Carryforward
Bond Premium Carryforward
Treasury Inflation-Protected Securities Issued at a Premium; Bond Premium Carryforward
Bond Premium Carryforward
Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated
Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated
Partners Distributive Share
Partners Distributive Share
Use of Controlled Corporations to Avoid the Application of Section 304
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
Allocation of Costs Under the Simplified Methods; Hearing
Deduction for Qualified Film and Television Production Costs
Net Investment Income Tax
Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor in Bankruptcy
Utility Allowances Submetering; Hearing Cancellation
Regulations Regardingthe Application of Section 172(h) Including Consolidated Groups; Correction
Additional Requirements for Charitable Hospitals; Hearing
Basis of Indebtedness of S Corporations to Their Shareholders; Hearing Cancellation
Additional Requirements for Charitable Hospitals: Public Hearings
New Markets Tax Credit Non-Real Estate Investments
Integrated Hedging Transactions of Qualifying Debt
Application of Section 172(h) Including Consolidated Groups
Integrated Hedging Transactions of Qualifying Debt
Integrated Hedging Transactions of Qualifying Debt
Allocation of Costs under the Simplified Methods
Dividend Equivalents from Sources within the United States; Amendment Correction
Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor in Bankruptcy: Hearing Cancellation
Deductions for Entertainment Use of Business Aircraft; Correction
Additional Requirements for Charitable Hospitals; Correction
Utility Allowances Submetering
Deductions for Entertainment Use of Business Aircraft
Reimbursed Entertainment Expenses
Health Insurance Premium Tax Credit; Correction
Basis of Indebtedness of S Corporations to Their Shareholders; Correction
Substantial Business Activities: Correction
Additional Requirements for Charitable Hospitals
Overall Foreign Loss Recapture on Property Dispositions
Treatment of Overall Foreign and Domestic Losses
Prohibited Payment Option under Single-Employer Defined Benefit Plan of Plan Sponsor In Bankruptcy
Financial Asset Securitization Investment Trusts
Property Transferred in Connection with Performance of Services under Section 83
Substantial Business Activities
Surrogate Foreign Corporations
Substantial Business Activities
Basis of Indebtedness of S Corporations to their Shareholders
Property Transferred in Connection with Performance of Services under Section83
Regulations Revising Rules Regarding Agency for Consolidated Group
Modifications to Definition of United States Property
Modifications to Definition of United States Property
Allocation of Mortgage Insurance Premiums
Local Lodging Expenses
Treatment of Gain Recognized with Respect to Stock in Certain Foreign Corporations Upon Distributions
Guidance under Sections 642 and 643 (Income Ordering Rules)
Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts
Deferral of Loss on Transactions between Members of a Controlled Group
Allocation of Earnings and Profits in Tax-Free Transfers from One Corporation to Another
Conduit Financing Arrangements; Correction
Allocation and Apportionment of Interest Expense; Hearing Cancellation
Apportionment of Tax Items Among the Members of a Controlled Group of Corporations; CFR Correction
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Correction
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property; Correction
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
Treasury Inflation-Protected Securities Issued at a Premium; Hearing Cancellation
Passive Activity Losses and Credits Limited: Hearing
Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension Plans; Correction
Dividend Equivalents from Sources Within the U.S.; Correction
Determination of Governmental Plan Status; Correction
Indian Tribal Government Plans; Correction
Determination of Governmental Plan Status; Correction
Indian Tribal Government Plans; Correction
Reporting of Specified Foreign Financial Assets; Correction
Reporting of Specified Foreign Financial Assets; Correction
Source of Income from Qualified Fails Charges
Reporting of Specified Foreign Financial Assets; Correction
Allocation and Apportionment of Interest Expense; Correction
Reporting of Specified Foreign Financial Assets; Correction
Furnishing Identifying Number of Tax Return Preparer
Foreign Tax Credit Splitting Events
Section 482: Methods to Determine Taxable Income in Connection with Cost Sharing Arrangement; Correction
Foreign Tax Credit Splitting Events
Section 482: Methods to Determine Taxable Income in Connection with Cost Sharing Arrangement; Correction
Definition of a Taxpayer
Application for Recognition as a 501(c)(29) Organization
Application for Recognition as a 501(c)(29) Organization
Dividend Equivalents from Sources within the United States
Indian Tribal Government Plans
Longevity Annuity Contracts
Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options under Defined Benefit Pension Plans
Determination of Governmental Plan Status
Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Indian Tribal Government Plans
Dividend Equivalents from Sources within the United States
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property: Public Hearing
Determination of Governmental Plan Status
Dividend Equivalents from Sources within the United States
Damages Received on Account of Personal Physical Injuries or Physical Sickness
Allocation and Apportionment of Interest Expense
Allocation and Apportionment of Interest Expense
Guidance Regarding Deduction and Capitalization ofExpenditures Related to Tangible Property
Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
Use of Differential Income Stream as Application of Income Method and as Consideration in Assessing Best Method
Use of Differential Income Stream as Consideration in Assessing Best Method
Tax Return Preparer Penalties under Section 6695
Corporate Reorganizations: Guidance on Measurement of Continuity of Interest
Corporate Reorganizations: Guidance on Measurement of Continuity of Interest
Guidance Regarding Foreign Base Company Sales Income
Reporting of Specified Foreign Financial Assets
Reporting of Specified Foreign Financial Assets
Application of Segregation Rules to Small Shareholders: Correction
Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options: Correction
New Markets Tax Credit Non-Real Estate Investments; Hearing Cancellation
Conduit Financing Arrangements
Indian Tribal Governmental Plans; Correction
Determination of Governmental Plan Status; Correction
Treasury Inflation-Protected Securities Issued at a Premium
Treasury Inflation-Protected Securities Issued at a Premium
Targeted Populations Under Section 45D(e)(2)
Passive Activity Losses and Credits Limited
Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options
Application of the Segregation Rules to Small Shareholders
Corporate Reorganizations; Allocation of Basis in All Cash D Reorganizations
Deduction for Qualified Film and Television Production Costs: Correction
Application of Section 108(e)(8) to Indebtedness Satisfied by a Partnership Interest
Indian Tribal Governmental Plans
Determination of Governmental Plan Status
Tax Accounting Elections on Behalf of Foreign Corporations; Withdrawal
Tax Return Preparer Penalties Under Section 6695; Hearing Cancellation
Modifications of Certain Derivative Contracts; Hearing Cancellation
Partner's Distributive Share
Redetermination of the Consolidated Net Unrealized Built-In Gain and Loss
Guidance Regarding the Treatment of Stock of a Controlled Corporation
Tax Return Preparer Penalties Under Section 6695; Correction
Deduction for Qualified Film and Television Production Costs
Deduction for Qualified Film and Television Production Costs
Tax Return Preparer Penalties Under Section 6695; Correction
Tax Return Preparer Penalties Under Section 6695
Retail Inventory Method
Implementation of Form 990; Correction
Elections Regarding Start-Up Expenditures, Corporation Organizational Expenditures, etc.; Correction
Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction
Section 67 Limitations on Estates or Trusts
Definition of Solid Waste Disposal Facilities for Tax-Exempt Bond Purposes; Correction
Certain Employee Remuneration in Excess of $1,000,000 Under Internal Revenue Code Section 162(m); Correction
Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correction
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correction
Methods of Accounting Used by Corporations that Acquire Assets of Other Corporations: Correction
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correcting Amendment
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credits: Correction
Modifications of Certain Derivative Contracts: Correction
Modifications of Certain Derivative Contracts: Correction
Modifications of Certain Derivative Contracts: Correction
Elections Regarding Start-up Expenditures, Corporation Organizational Expenditures, and Partnership Organizational Expenses
Health Insurance Premium Tax Credit
Corporate Reorganizations; Distributions under Sections 368(a)(1)(D) and 354(b)(1)(B): Correction
Methods of Accounting Used by Corporations that Acquire Assets of Other Corporations
Election of Reduced Research Credit
Guidance under Section 956 for Determining Basis of Property Acquired in Certain Nonrecognition Transactions; Correction
Modifications of Certain Derivative Contracts
Modifications of Certain Derivative Contracts
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credit
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credit
Determining Amount of Taxes Paid for Purposes of Foreign Tax Credit
New Markets Tax Credit Non-Real Estate Investments:Correction
Encouraging New Markets Tax Credit Non-Real Estate Investments: Correction
Modification of Regulations under Dodd-Frank Wall Street Reform and Consumer Protection Act
Guidance under Section 956 for Determining Basis of Property Acquired in Certain Nonrecognition Transactions
Requirements for Taxpayers Filing Form 5472; Correction
Requirements for Taxpayers Filing Form 5472; Correction
Deduction Limitation for Certain Employee Remuneration in Excess of $1,000,000
Alternative Simplified Credit
Claims for Credit or Refund
Requirements for Taxpayers Filing Form 5472
Requirements for Taxpayers Filing Form 5472
Encouraging New Markets Tax Credit Non-Real Estate Investments
New Markets Tax Credit Non-Real Estate Investments: Public Hearing
Controlled Groups; Deferral of Losses
Controlled Groups; Deferral of Losses; Correction
Treatment of Property Used to Acquire Parent Stock or Securities in Certain Triangular Reorganizations Involving Foreign Corporations
Reduction of Foreign Tax Credit Limitation Categories; Correction
Modifications to Treatment of Aircraft and Vessel Leasing Income
Controlled Groups; Deferral of Losses
Guidance under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock; Correction
Guidance Concerning the Exclusion of Section 61 Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity
Clarification of Controlled Group Qualification Rules
Reduction of Foreign Tax Credit Limitation Categories under Section 904(d)
Guidance under Section 1502: Amendment of Matching Rule for Certain Gains on Member Stock; Correction
Property Traded on Established Market: Hearing Cancellation
Sales-Based Royalties and Vendor Allowances: Public Hearing
Guidance under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock
Time and Manner for Electing Capital Asset Treatment for Certain Self-Created Musical Works
Hybrid Retirement Plans; Correction
Source Rules Involving U.S. Possessions and Other Conforming Changes; Correction
Nuclear Decommissioning Funds; Correction
Property Traded on Established Market
Modifications of Debt Instruments
Source of Income From Qualified Fails Charges; Correction
Hybrid Retirement Plans; Correction
Hybrid Retirement Plans
Sales-Based Royalties and Vendor Allowances
Farmerand Fisherman Income Averaging
Requirement of a Statement Disclosing Uncertain Tax Positions
Source of Income from Qualified Fails Charges
Revised Regulations Concerning Section 403(b) Tax-Sheltered Annuity Contracts: Correction
Revised Regulations Concerning Section 403(b) Tax-Sheltered Annuity Contracts: Correction
Hybrid Retirement Plans
Additional Rules Regarding Hybrid Retirement Plans
Exclusions From Gross Income of Foreign Corporations; Correction
Requirements of a Statement Disclosing Uncertain Tax Positions; Correction
Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations, etc.; Correction
Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations, etc.; Correction
Requirement of a Statement Disclosing Uncertain Tax Positions
Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction
Qualified Zone Academy Bonds; Obligations of States and Political Subdivisions; Correction
Clarification to Section 6411 Regulations
Modifications of Debt Instruments; Hearing Cancellation
Application of Section 108(i) to Partnerships and S Corporations
Guidance Regarding Deferred Discharge of Indebtedness Income of Corporations and Deferred Original Issue Discount Deductions
Extended Carryback of Losses to or from Consolidated Groups: Correction
Build-in Gains and Losses Under Section 382(h); Correction
Extended Carryback of Losses to or from a Consolidated Group
Built-in Gains and Losses under Section 382(h)
Contributed Property
Modifications of Debt Instruments
Qualified Nonpersonal Use Vehicles
Diversification Requirements for Certain Defined Contribution Plans
AJCA Modifications to the Section 6011 Regulations; Correction
AJCA Modifications to the Section 6011 Regulations; Correction
Furnishing Identifying Number of Tax Return Preparer; Hearing
Exclusions From Gross Income of Foreign Corporations; CFR Correction
Consolidated Returns; Intercompany Obligations; CFR Correction
Furnishing Identifying Number of Tax Return Preparer
Unified Rule for Loss on Subsidiary Stock; Correction
Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income
Reduced 2009 Estimated Income Tax Payments for Individuals with Small Business Income
Use of Controlled Corporations To Avoid the Application of Section 304; Correction
Basis Reporting by Securities Brokers and Basis Determination for Stock; Correction
Modification to Consolidated Return Regulation: Permitting an Election to Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization
Information Reporting Requirements Under Internal Revenue Code Section 6039; Correction
Information Reporting Requirements Under Internal Revenue Code Section 6039; Correction
Employee Stock Purchase Plans Under Internal Revenue Code Section 423; Correction
Corporate Reorganizations; Distributions under sections 368(a)(1)(D) and 354(b)(1)(B)
Modification to Consolidated Return Regulation Permitting an Election: Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization; Correction
Clarification of Controlled Group Qualification Rules
Modification to Consolidated Return Regulation Permitting an Election: Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization
Allocations and Reporting of Mortgage Insurance Premiums; Correction
Suspension or Reduction of Safe Harbor Nonelective Contributions
Special Rules To Reduce Section 1446 Withholding; Correction
Gain Recognition Agreements With Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction
Guidance Regarding Foreign Base Company Sales Income
Guidance Regarding Foreign Base Company Sales Income; Correction
Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Application of Section 367 to a Section 351 Exchange, etc.: Correction
Applications: Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1), etc.; Correction
Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations; Correction
Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities; Correction
Section 482; Methods to Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction
Section 482; Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement; Correction
Further Guidance on the Application of Section 409A to Nonqualified Deferred Compensation Plans; 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; Hearing Cancellation
Section 108(e)(8) Application to Partnerships; Hearing Cancellation
Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1): Treatment of Gain Recognized under Section 301(c)(3) for Purposes of Section 1248
Application of Section 367 to a Section 351 Exchange Resulting from a Transaction Described in Section 304(a)(1)
Consolidated Returns; Intercompany Obligations; Correction
Consolidated Returns; Intercompany Obligations; Correction
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Guidance Regarding Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Guidance Regarding the Treatment of Stock of a Controlled Corporation Under Section 355(a)(3)(B); Correction
Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities
Section 707 Regarding Disguised Sales, Generally
Swap Exclusion for Section 1256 Contracts
Details Information
Comments
View AllSubmitter: Bloomfield, Micah Posted: 09/27/2011 ID: IRS-2011-0029-0002
Dec 15,2011 11:59 PM ET
Submitter: Bautz, Peter Posted: 12/15/2011 ID: IRS-2011-0029-0004
Dec 15,2011 11:59 PM ET
Submitter: Desai, Pinank Posted: 12/15/2011 ID: IRS-2011-0029-0005
Dec 15,2011 11:59 PM ET
Submitter: Wierzynski, Barbara Posted: 12/16/2011 ID: IRS-2011-0029-0006
Dec 15,2011 11:59 PM ET
Submitter: Baker, Richard Posted: 12/20/2011 ID: IRS-2011-0029-0008
Dec 15,2011 11:59 PM ET
Related Documents
More