Internal Revenue Bulletin: 2005-19
May 9, 2005
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 2005.
Medicaid rebates. This ruling holds that Medicaid rebates incurred by a pharmaceutical manufacturer are purchase price adjustments that are subtracted from gross receipts in determining gross income. Rev. Rul. 76-96 suspended in part.
Form 8854, Initial and Annual Expatriation Information Statement, has been revised to reflect the substantial revisions made to the individual expatriation provisions of sections 877 and 6039G of the Code and the enactment of new section 7701(n) by section 804 of the American Jobs Creation Act of 2004. Revised Form 8854 is required to be filed by every individual who loses U.S. citizenship or terminates long-term residency after June 3, 2004. The purpose of this notice is to provide guidance with respect to the filing of the revised Form 8854 by such former citizens and former long-term residents. Notices 97-19 and 98-34 obsoleted in part.
This document contains corrections to proposed regulations (REG-163314-03, 2005-14 I.R.B. 835) that provide that a transaction will qualify for nonrecognition treatment under sections 332, 351, or 368 of the Code only if there is a transfer and a receipt of net value.
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