Internal Revenue Bulletin:  2004-19 

May 10, 2004 

INCOME TAX


Rev. Rul. 2004-44 Rev. Rul. 2004-44

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2004.

T.D. 9120 T.D. 9120

Final, temporary, and proposed regulations under section 861 of the Code provide an alternative method for valuing assets for purposes of apportioning interest expense under the tax book value method contained in temporary regulations section 1.861-9T(g). For that limited purpose, the alternative method allows taxpayers to determine the adjusted basis of all tangible property under the alternative depreciation system of section 168(g). The regulations also provide guidance on electing the alternative method. The alternative method provides taxpayers with the option of determining the adjusted bases of both foreign and domestic assets under one consistent depreciation regime for temporary regulations section 1.861-9T(g) apportionment purposes and helps reduce the basis disparity between foreign and domestic assets which can occur under the current regulations. A public hearing on the proposed regulations is scheduled for July 19, 2004.

REG-129447-01 REG-129447-01

Final, temporary, and proposed regulations under section 861 of the Code provide an alternative method for valuing assets for purposes of apportioning interest expense under the tax book value method contained in temporary regulations section 1.861-9T(g). For that limited purpose, the alternative method allows taxpayers to determine the adjusted basis of all tangible property under the alternative depreciation system of section 168(g). The regulations also provide guidance on electing the alternative method. The alternative method provides taxpayers with the option of determining the adjusted bases of both foreign and domestic assets under one consistent depreciation regime for temporary regulations section 1.861-9T(g) apportionment purposes and helps reduce the basis disparity between foreign and domestic assets which can occur under the current regulations. A public hearing on the proposed regulations is scheduled for July 19, 2004.

T.D. 9122 T.D. 9122

Final regulations under section 1502 of the Code relate to the determination of the basis of the stock of the common parent of a consolidated group when such stock is acquired in a transaction that qualifies as a group structure change. These regulations amend current regulations section 1.1502-31 modifying the application of the net asset basis rule in group structure changes.


More Internal Revenue Bulletins