IRS Logo
Print - Click this link to Print this page

January 2006 Plain Language Regulations

Residence Rules Involving U.S. Possessions
These final regulations provide rules for determining whether an individual is a bona fide resident of American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands.  The Internal Revenue Code provides special rules applicable to bona fide residents of these U.S. possessions.  Accordingly, the determination of whether an individual is a bona fide resident of a particular possession may affect whether an individual files an income tax return with the IRS, the possession tax authority, or both, and whether the individual is entitled to exclude certain income from U.S. gross income.  Individuals who become or cease to be bona fide residents of a U.S. possession may be required to notify the IRS of their change in residence.  In addition, bonda fide residents of a U.S. possession may have to file other information returns with the IRS or the possessions tax authority. 
TD 9248.  Published January 31, 2006.
Download Full Text

Allocation and Apportionment of Expenses; Alternative Method for Determining Tax Book Value of Assets
These final regulations provide an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of section 1.861-9T. The alternative tax book value method, which is elective, is intended to minimize basis disparities between foreign and domestic assets of taxpayers that may arise when taxpayers use adjusted tax basis to value assets under the tax book value method of expense apportionment. TD 9247.  Published January 30, 2006.
Download Full Text

Entities Created or Organized in More Than One Jurisdiction
Some business entities may be recognized under state or foreign law as created or organized in more than one jurisdiction at the same time ("dually chartered entities").  These final regulations provide clarification regarding how to determine the federal tax classification (e.g. corporation, partnership, or an entity disregarded as separate from its owner) of a dually chartered entity and how to determine whether a dually chartered entity is domestic or foreign.  The previous temporary regulations (TD 9153) are removed.  TD 9246.  Published January 30, 2006.
Download Full Text

Designated Roth Accounts Under Section 402A
This document contains proposed regulations under sections 402(g), 402A, 402(b), and 408A of the Internal Revenue Code relating to designated Roth accounts.  These regulations will affect administrators of, employers maintaining, participants in, and beneficiaries of Roth IRAs and trustees of Roth IRAs.
REG-146459-05.  Published January 26, 2005.
Download Full Text

Revision of Income Tax Regulations under Sections 367, 884 and 6038B dealing with Statutory Mergers or Consolidations under Section 368(a)(1)(A)
A final regulation is being published that would provide certain international tax rules to account for statutory mergers and consolidations effected pursuant to foreign law involving one or more foreign corporations.  A companion final regulation provides that certain statutory mergers and consolidations will qualify for tax-exempt treatment if they are affected pursuant to foreign law.  In light of this change to the treatment of statutory mergers and consolidations, this document contains amendments to the international tax regulations that would account for statutory mergers and consolidations under foreign law.  TD 9243.  Published January 26, 2006.
Download Full Text

Treatment of Excess Loss Accounts
Section 1.1502-19 provides rules for a member to include in income its excess loss account in the stock of another member of the consolidated group.  These proposed regulations provide guidance when the member's original shares have an excess loss account or the member would otherwise determine that new shares would have an excess loss account at the time of a basis adjustment or determination under the Internal Revenue Code.
REG-138879-05.  Published January 26, 2006
Download Full Text

Allocation of Basis; Treatment of Excess Loss Accounts
These final regulations clarify that the basis of each share of stock received in certain tax-free transactions shall be the same as the basis of the share or shares of stock exchanged therefore.  The final regulations provide that a taxpayer may designate which share of stock is received in exchanged for or with respect to a particular share of stock held prior to the tax-free transaction.  Section 1.1502-19 provides rules for a member to include in income its excess loss account in the stock of another member of the consolidated group.  These temporary regulations provide guidance when the member's original shares have an excess loss account or the member would otherwise determine that new share would have an excess loss account at the time of a basis adjustment or determination under the Internal Revenue Code.
TD 9244.  Published January 26, 2006.
Download Full Text

Statutory Mergers and Consolidations
These final regulations define the term statutory merger or consolidation as used in the Internal Revenue Code.  These final regulations remove the requirement in temporary regulations that transactions must be carried out under domestic law in order to qualify as a statutory merger or consolidation.  These regulations also provide that a transaction may qualify even if it involves foreign entities.  These regulations also provide a special rule that addresses the qualification as a statutory merger or consolidation of a transaction involving certain entities that are disregarded as entities separate from their corporate owners for Federal income tax purposes.
TD 9242.  Published January 26, 2006.
Download Full Text

Reporting Requirements for Widely Held Fixed Investment Trusts
These final regulations provide the reporting rules for the trustees of certain investment trusts and for the brokerage firms that hold interests, as middlemen, for investors in these trusts. TD 9241.  Published January 24, 2006.
Download Full Text

Guidance Under Subpart F Relating to Partnerships
These regulations contain rules for determining whether a controlled foreign corporation's (CFC's) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception).  These regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs.
TD 9240.  Published January 17, 2006.
Download Full Text

Guidance Under Subpart F Relating to Partnerships
These regulations contain rules for determining whether a controlled foreign corporation's (CFC's) distributive share of partnerships income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception).  These regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs.
REG-106418-05.  Published January 17, 2006.
Download Full Text

Employers' Annual Federal Tax Program (Form 944)
These final and temporary regulations issued under regulations sections 31.6011(a)-1, 31,6011(a)-4, and 31.6302-1 relate to the time for employers to file returns and make deposits under FICA and returns of income tax withheld.  These regulations require employers who receive notification of qualification for the Employers' Annual Federal Tax Program (Form 944) to file Form 944, Employer's Annual Federal Tax Return, annually instead of Form 941, Employer's Quarterly Federal Tax Return, quarterly beginning in the 2006 taxable year.  These regulations also permits most employers who file Form 944 to remit accumulated employment taxes annually with their return and modify the lookback period and de minimis deposit rule for these employers.  In regulations as well as technical revisions to section 31.6302-1.
TD 9239.  Published January 3, 2006.
Download Full Text

Employers' Annual Federal Tax Program (Form 944)
This notice of proposed rulemaking by cross reference to temporary regulations provides proposed amendments to regulations sections 31.6011(a)-1, 31.6011(a)-4, and 31.6302-1 relating to the time for employers to file returns and make deposits under FICA and returns of income tax withheld.  These regulations would require employers who receive notification of qualification for the Employers Annual Federal Tax Program (Form 944) to file Form 944, Employer's Annual Federal Tax Return, annually instead of Form 941, Employer's Quarterly Federal Tax Return, quarterly beginning in the 2006 taxable year.  These proposed regulations also would permit most employers who file Form 944 to remit accumulated employment taxes annually with their return and modify the lookback period and de minimis deposit rule for these employers.  In addition to rules related to the Employers' Annual Federal Tax Program (Form 944), these proposed regulations provide an additional method for quarterly return filers to determine whether the amount of accumulated employment taxes is considered de minimis.  REG-148568-04.  Published January 3, 2006.
Download Full Text

Designated Roth Contributions to Cash or Deferred Arrangements under Section 401(k)
These regulations provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements described in section 401(k).  These regulations affect section 401(k) plans that provide for designated Roth contributions and participants eligible to make elective contributions under these plans.
TD 9237.  Published January 3, 2006.
Download Full Text


 «« Go to February 2006 ------------- Browse for more ------------- Go to December 2005 »»

Main Plain Language Regulations page

Page Last Reviewed or Updated: 09-Jan-2014