Internal Revenue Bulletin: 2004-42
October 18, 2004
Final regulations under section 6091 of the Code relate to the filing of hand-carried returns and other documents, remove references to IRS titles and organizational units that have been superseded, and replace them with updated references to offices and officers that are sufficiently flexible to take into account any future changes to structure or operations of the IRS.
Proposed regulations under section 269B of the Code generally treat a stapled foreign corporation as a domestic corporation for U.S. federal income tax purposes, unless the stapled foreign corporation and the corresponding domestic stapled corporation are foreign-owned. Under the regulations, while a stapled foreign corporation is not an includible corporation under section 1504(b) for most purposes, it may be an includible corporation for purposes of regulations sections 1.904(i)-1 and 1.861-11T(d)(6). They also provide that a conversion of a domestic corporation to a foreign corporation (or vice versa) as a result of section 269B is treated as an F reorganization; limit the application of treaty benefits to stapled foreign corporations; provide special collection procedures for tax liabilities of stapled foreign corporations; address issues involving multiple classes of stock in determining whether a foreign corporation is a stapled foreign corporation; and provide the Commissioner with authority to disregard certain stapled stock structures involving related parties. A public hearing is scheduled for December 15, 2004.
The Service is suspending certain income limitation requirements under section 42 of the Code for certain low-income housing credit properties in Florida as a result of the devastation caused by Hurricane Charley and Hurricane Frances.
Per diem allowances. This procedure provides rules for deeming substantiated the amount of certain reimbursed traveling expenses of an employee as well as optional rules for determining the amount of deductible meals and incidental expenses while traveling away from home. Rev. Proc. 2003-80 superseded.
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