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March 2006 Plain Language Regulations

Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit
These regulations revise final regulations under section 417(a)(3) of the Internal Revenue Code that were published in 2003 concerning content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuitities payable under certain retirement plans. The 2003 regulations specify requirements for disclosing the relative value of optional forms of benefit payable from certain retirement plans.  TD 9256.  Published March 24, 2006.
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Agent of the Group for Consolidated Groups with Foreign Parents
In certain circumstances, a foreign entity involved in a so-called inversion transaction is treated as a domestic corporation for all federal income tax purposes.  Accordingly, a foreign entity could become the common parent of a consolidated group.  As common parent, this entity would become the sole agent for the group with respect to federal income tax matters.  Having a foreign entity act as the agent for the group may not always be efficient or practical for tax administration.  These regulations allow the IRS to designate a domestic member of the group to act as the group's sole agent in place of such a common parent.  TD 9255.  Published March 14, 2006.
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Agent of the Group for Consolidated Groups with Foreign Parents
In certain circumstances, a foreign entity involved in a so-called inversion transaction is treated as a domestic corporation for all federal income tax purposes. Accordingly, a foreign entity could become the common parent of a consolidated group.  As the common parent, this entity would become the sole agent for the group with respect to federal income tax matters.  Having a foreign entity act as the agent for the group may not always be efficient or practical for tax administration.  These regulations allow the IRS to designate a domestic member of the group to act as the group's sole agent in place of such a common parent.  REG-164247-05.  Published March 14, 2006.
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Revisions to Regulations Relating to Withholding of Tax on Certain U.S. Source Income Paid to Foreign Persons and Revisions of Information Reporting Regulations
This document contains final regulations relating to the withholding of tax under sections 1441 and 1442 on certain U.S. source income paid to foreign persons and related requirements governing collection, deposit, refunds, and credits of withheld amounts under sections 1461 through 1463.  These regulations affect persons making payments of U.S. source income to foreign persons and foreign persons claiming benefits under a U.S. income tax treaty.
TD 9253.  Published March 14, 2006.
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Guidance under Section 1502; Suspension of Losses on Certain Stock Dispositions
This document contains final regulations under section 1502 of the Internal Revenue Code of 1986.  The regulations apply when a member of a consolidated group sells subsidiary stock at a loss.  They also apply when a member holds loss shares of subsidiary stock and the subsidiary ceases to be a member of the group.  The regulations generally limit duplicated losses by redetermining stock basis, suspending stock loss, or adjusting inside loss.  These regulations finalize section 1.1502-35T without substantive change.  TD 9254.  Published March 14, 2006.
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Page Last Reviewed or Updated: 22-Jan-2014