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March 2007 Plain Language Regulations

PLEASE NOTE: Ending with the publication of REG-100841-97 on March 5, 2007 (see below), the IRS stopped publishing its proposed regulations on IRS.gov.  If you would like to review or provide comments on any other proposed regulation published on or after March 5, 2007, please visit www.Regulations.gov and select "Internal Revenue Service" from the Agency drop-down list.


Agreements for Payment of Tax Liabilities in Installments
Section 6159 of the Internal Revenue Code allows the IRS to enter into agreements with taxpayers for the payment of tax liabilities in installments.  The principal purpose of this project is to update the regulations under section 6159 to reflect various amendments to that section and related statutes.  The proposed regulations govern the acceptance and rejection of installment agreement, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. 
REG-100841-97.  Published March 5, 2007.
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Distributions of Stock in Certain Tax-Free Reorganizations
While most tax-free reorganization provisions require one corporation that acquires another corporation to issue stock to shareholders of the corporation being acquired, the IRS has not required taxpayers to issue stock in an all cash sale of assets between two corporations when the same person or persons own the same proportion of stock in both corporations.  Recent regulations provide guidance on when the same person or persons are treated as owning the same proportion of stock in both the acquiring and acquired corporation and therefore stock does not have to be issued in an all cash sale of assets between two corporations.  These regulations provide additional guidance on this situation and the effect on certain related party triangular reorganizations. REG-157834-06.  Published March 1, 2007.
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Depreciation Relating to Like-Kind Exchanges or Involuntary Conversions
These regulations instruct taxpayers how to determine the annual depreciation allowance for depreciation property that is either acquired or relinquished in a like-kind exchange or an involuntary conversion.  TD 9314.  Published March 1, 2007.
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Distributions of Stock in Certain Tax-Free Reorganizations
While most tax-free reorganization provisions require one corporation that acquires another corporation to issue stock to shareholders of the corporation being acquired, the IRS has not required taxpayers to issue stock in an all cash sale of assets between two corporations when the same person or persons own the same proportion of stock in both corporations.  Recent regulations provide guidance on when the same person or persons are treated as owning the same proportion of stock in both the acquiring and acquired corporation and therefore stock does not have to be issued in an all cash sale of assets between two corporations.  These regulations provide additional guidance on this situation and the effect on certain related party triangular reorganizations. 
TD 9313.  Published March 1, 2007.
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Page Last Reviewed or Updated: 22-Jan-2014