IRS Logo
Print - Click this link to Print this page

April 2006 Plain Language Regulations

The Tacking Rule of the Life-Nonlife Consolidated Return Regulations
In general, a life insurance company must be affiliated with nonlife corporations for a five year period before such life insurance company may join in the filing of a consolidated return with such nonlife corporations.  The tacking rule of the life-nonlife consolidated return regulations provides an exception to the five-year apply.  These regulations modify the requirements of the tacking rule by eliminating one of the five conditions of the tacking rule.  TD 9258.  Published April 25, 2006.
Download Full Text

The Tacking Rule of the Life-Nonlife Consolidated Return Regulations
In general, a life insurance company must be affiliated with nonlife corporations for a five year period before such life insurance company may join in the filing of a consolidated return with such nonlife corporations.  The tacking rule of the life-nonlife consolidated return regulations provides an exception to the five-year affiliation requirement.  Five conditions must be met in order for the tacking rule to apply.  These regulations propose the modification of the requirements of the tacking rule by eliminating one of the five conditions of the tacking rule. 
REG-133036-05.  Published April 25, 2006.
Download Full Text

Application of Separate Limitations to Dividends from Noncontrolled Section 902 Corporations
The American Jobs Creation Act of 2004 amended the foreign tax credit treatment of dividends from noncontrolled section 902 corporations effective for post-2002 tax years, and the Gulf Opportunity Zone Act of 2005 permitted taxpayers to elect to defer the effective date of these amendments until post-2004 tax years.  The temporary regulations provide guidance concerning these amendments and primarily affect corporations claiming foreign tax credits.  TD 9260.  Published April 25, 2006.
Download Full Text

Application of Separate Limitations to Dividends from Noncontrolled Section 902 Corporations
The American Jobs Creation Act of 2004 amended the foreign tax credit treatment of dividends from noncontrolled section 902 corporations effective for post-2002 tax years, and the Gulf Opportunity Zone Act of 2005 permitted taxpayers to elect to defer the effective date of these amendments until post-2004 tax years.  The proposed regulations provide guidance concerning these amendments and primarily affect corporations claiming foreign tax credits. 
REG-144784-02.  Published April 25, 2006.
Download Full Text

Amendment to Statutory Mergers and Consolidations
These final regulations amend final regulations (TD 9242) published in the Federal Register on January 26, 2006 concerning certain tax-free reorganizations under section 368(a)(1)(A) of the Internal Revenue Code known as statutory mergers and consolidations.  This amendment provides transitional relief for certain transactions initiated before January 26, 2006.  TD 9259.  Published April 25, 2006.
Download Full Text

Application of Section 338 to Insurance Companies
This document contains a notice of proposed rulemaking by cross-reference to temporary regulations that provide guidance relating to the determination of adjusted basis of amortizeable intangibles, increases in reserves after a deemed asset sale under section, and the carryover of an election to use a company's historical loss payment pattern. REG-146384-05.  Published April 10, 2006.
Download Full Text

Application of Section 338 to Insurance Companies
This document contains final regulations that apply to a deemed sale or acquisition of an insurance company's assets, to a sale or acquisition of an insurance trade or business, and to the acquisition of insurance contracts through assumption reinsurance.  It also contains final regulations concerning the effect of certain corporate liquidations and reorganizations on certain tax attributes of insurance companies.  This document also contains temporary regulations relating to the determination of adjusted basis of amortizable section 197 intangibles, increases in reserves after a deemed asset sale and the carryover of an election to use a company's historical loss payment pattern.
TD 9257.  Published April 10, 2006.
Download Full Text


«« Go to May 2006 --------------------- Browse for more --------------------- Go to March 2006 »»

Main Plain Language Regulations page

Page Last Reviewed or Updated: 22-Jan-2014