Internal Revenue Bulletin: 2005-12
March 21, 2005
Fringe benefits aircraft valuation formula. The Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charges in effect for the first half of 2005 are set forth for purposes of determining the value of noncommercial flights on employer-provided aircraft under section 1.61-21(g) of the regulations.
Final regulations under section 7701 of the Code clarify that a disregarded entity (an entity that is not treated as separate from its owner) is treated as a separate entity for purposes of any federal tax liability for which it is liable.
Final regulations under section 860F of the Code relate to the application of the unified partnership audit procedures to disputes regarding the ownership of residual interests in a Real Estate Mortgage Investment Conduit (REMIC).
Final regulations under section 817 of the Code remove provisions of the regulations that apply a look-through rule to assets of a nonregistered partnership for purposes of satisfying the diversification requirements of section 817(h).
This notice clarifies and modifies Notice 2004-80 to provide additional guidance for material advisors who are required to comply with sections 6111 and 6112 of the Code, as amended, and to grant an extension of time for material advisors to comply with the new filing requirements under section 6111 as previously provided in Notice 2004-80 and Notice 2005-17. Notices 2004-80 and 2005-17 clarified and modified.
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