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September 2006 Plain Language Regulations

General Allocation and Accounting Regulations under Section 141
Generally, interest on a State or local bond is excluded from gross income. However, the exclusion does not apply to a private activity bond unless the bond is a qualified bond.  The proposed regulations would provide general rules on the allocation of and accounting for bond proceeds for purposes of the private activity bond restrictions which apply to tax-exempt governmental bonds.  Special rules are also provided for certain projects that are used by both a private business and government (mixed-used project).  Finally, these regulations provide that a partnership in which all the partners are governmental persons are disregarded and any use of the financed property by the partnership is treated as governmental use.
REG-140379-02.  Published September 26, 2006.
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Elimination of Country-by-Country Reporting to Shareholders of Foreign Taxes Paid by Regulated Investment Companies
These proposed regulations would generally eliminate country-by-country reporting by a regulated investment company (RIC) to its shareholders of foreign source income that the RIC takes into account and foreign taxes that it pays. Under these regulations, the Treasury Department and the IRS would continue to require the reporting of per-country information by RICs to the IRS because this information remains relevant to the IRS's monitoring compliance with the rules that disallow credits for refundable and noncompulsory payments and for taxes paid to certain countries.  The regulations would affect certain RICs that pay foreign taxes and the shareholders of those RICs.
REG-105248-04.  Published September 18, 2006.
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Attained Age of the Insured Under Section 7702
This final regulation explains how to determine the attained age of an insured for purposes of testing whether a contract qualifies as a life insurance contract for Federal income tax purposes. TD 9287.  Published September 13, 2006.
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Railroad Track Maintenance Credit
Recent amendments to the Internal Revenue Code allow a credit for certain expenditures paid or incurred by a Class II railroad, a Class III railroad, and other eligible taxpayers to maintain railroad track and other related track structure of a Class II or Class III railroad.  These regulations explain the requirements that must be met for a taxpayer to qualify for the railroad track maintenance credit and how to determine the amount of that credit.  TD 9286.  Published September 8, 2006.
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Railroad Track Maintenance Credit
Recent amendments to the Internal Revenue Code allow a credit for certain expenditures paid or incurred by a Class II railroad, a Class III railroad, and other eligible taxpayers to maintain railroad track and other related track structure of a Class II or Class III railroad.  These regulations explain the requirements that must be met for a taxpayer to qualify for the railroad track maintenance credit and how to determine the amount of that credit. 
REG-142270-05. Published September 8, 2006.
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Income and Currency Gain or Loss with Respect to a Section 987 QBU
Generally, a taxpayer and any of its business units must make all determinations under the Internal Revenue Code in the functional currency of such taxpayer or unit.  A taxpayer's functional currency is, depending on the circumstances, either the U.S. dollar or in the case of a qualified business unit, the currency of the economic environment in which the qualified business unit conducts a significant amount of activities and in which it keeps its books and records.  In the case of a taxpayer with a qualified business unit which operates in a functional currency that is different from that of the taxpayer, the taxpayer must translate the unit's income and determine currency gain or loss with respect to the unit's functional currency operations under section 987.  These regulations provide guidance under section 987 regarding the determination of income and loss of the qualified business unit and the timing, amount, character, and source of the unit's currency gain or loss. 
REG-208270-86. Published September 7, 2006.
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Nonaccrual-Experience Method of Accounting Under Section 448(d)(5)
These final regulations provide rules relating to the use of a nonaccrual-experience method of accounting by taxpayers using an accrual method of accounting and performing services.  These final regulations affect qualifying taxpayers that want to adopt, change to, or change a nonaccrual-experience method of accounting under section 448(d)(5) of the Internal Revenue Code.  The nonaccrual-experience method is a method of accounting that allows the taxpayers to exclude from income certain amounts that, on the basis of a taxpayer's experience, would not be collected. 
TD 9285.  Published September 6, 2006.
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Collection after Assessment
The Internal Revenue Code and accompanying regulations provide that a tax may be collected for up to 10 years after it is properly assessed.  The revisions to the regulations incorporate changes to the Code that were made in 1998.  These changes limit the IRS's ability, as of January 1, 2000, to enter into agreements to extend the statutory period for collecting a tax.  TD 9284.  Published September 6, 2006.
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Page Last Reviewed or Updated: 22-Jan-2014