Internal Revenue Bulletin:  2004-36 

September 7, 2004 

INCOME TAX


Rev. Rul. 2004-69 Rev. Rul. 2004-69

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 September 2004.

T.D. 9143 T.D. 9143

Temporary, final, and proposed regulations under section 861 of the Code provide that deductions for charitable contributions (as defined in section 170(c)) are definitely related and allocable to all of the taxpayer's gross income and are apportioned on the basis of income from sources within the United States. The final regulations, which provide that deductions for charitable contributions are not definitely related to any gross income and therefore are ratably apportioned between or among the statutory and residual groupings, are removed. The proposed regulations withdraw proposed regulations, INTL-116-90, 1991-1 C.B. 949. A public hearing on the proposed regulations is scheduled for December 2, 2004. INTL-116-90 withdrawn.

REG-208246-90 REG-208246-90

Temporary, final, and proposed regulations under section 861 of the Code provide that deductions for charitable contributions (as defined in section 170(c)) are definitely related and allocable to all of the taxpayer's gross income and are apportioned on the basis of income from sources within the United States. The final regulations, which provide that deductions for charitable contributions are not definitely related to any gross income and therefore are ratably apportioned between or among the statutory and residual groupings, are removed. The proposed regulations withdraw proposed regulations, INTL-116-90, 1991-1 C.B. 949. A public hearing on the proposed regulations is scheduled for December 2, 2004. INTL-116-90 withdrawn.

T.D. 9144 T.D. 9144

Final regulations under section 421 of the Code provide guidance to taxpayers who are granted statutory stock options (i.e., incentive stock options and options granted under an employee stock purchase plan) and corporations who grant such options. The regulations also provide rules for the creation and operation of a statutory stock option plan.

T.D. 9146 T.D. 9146

Final, temporary, and proposed regulations under section 179 of the Code provide rules for making and revoking elections to expense the cost of certain depreciable business property. The regulations apply for property placed in service in taxable years beginning after 2002 and before 2006. A public hearing on the proposed regulations is scheduled for November 30, 2004.

REG-152549-03 REG-152549-03

Final, temporary, and proposed regulations under section 179 of the Code provide rules for making and revoking elections to expense the cost of certain depreciable business property. The regulations apply for property placed in service in taxable years beginning after 2002 and before 2006. A public hearing on the proposed regulations is scheduled for November 30, 2004.

REG-129771-04 REG-129771-04

Proposed regulations under section 951(a) of the Code provide guidance for determining a United States shareholder’s pro rata share of a controlled foreign corporation’s (CFC’s) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, previously excluded subpart F income withdrawn from foreign base company shipping operations, and amounts determined under section 956. A public hearing is scheduled for November 18, 2004.

Announcement 2004-67 Announcement 2004-67

This document contains corrections to A-14 in Notice 2004-2, 2004-2 I.R.B. 269, relating to Health Savings Accounts. Notice 2004-2 corrected.


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