Internal Revenue Bulletin:  2004-40 

October 4, 2004 

INCOME TAX


T.D. 9154 T.D. 9154

Temporary and proposed regulations under section 1502 of the Code extend the time for consolidated groups to make elections, and permit them to amend or revoke prior elections, concerning methods for determining allowable loss on a disposition of subsidiary stock.

REG-135898-04 REG-135898-04

Temporary and proposed regulations under section 1502 of the Code provide that the application of the deemed waiver rule of regulations section 1.1502-32T(b)(4)(v), which denied the use of excess losses in cases in which such denial was not intended, is elective.

REG-129274-04 REG-129274-04

Temporary and proposed regulations under section 1502 of the Code provide that the application of the deemed waiver rule of regulations section 1.1502-32T(b)(4)(v), which denied the use of excess losses in cases in which such denial was not intended, is elective.

T.D. 9157 T.D. 9157

Final regulations under section 988 of the Code provide for the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayer’s functional currency. This regulation generally provides that taxpayers should apply the existing rules under section 1275 to nonfunctional currency contingent payment debt instruments in the currency in which the debt instrument is denominated, and should then translate those amounts into the taxpayer’s functional currency using the rules provided. In addition, a rule is provided to determine the currency in which the calculations should be made, in the case of a multi-currency debt instrument. Announcement 99-76 obsolete.

Announcement 2004-75 Announcement 2004-75

This document describes rules that the IRS and Treasury may include in proposed regulations (REG-106679-04) regarding the proper timing of income or deduction attributable to an interest-only regular interest in a Real Estate Mortgage Investment Conduit (REMIC). This document also invites comments from the public.


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