Internal Revenue Bulletin: 2005-21
May 23, 2005
Table of Contents
Insurance companies; interest rate tables. Prevailing state assumed interest rates are provided for the determination of reserves under section 807 of the Code for contracts issued in 2004 and 2005. Rev. Rul. 92-19 supplemented in part.
Designation of dividends; regulated investment company (RIC). This ruling provides guidance that allows a RIC, in making the dividend designations permitted by sections 852, 854, and 871 of the Code, to designate the maximum amount permitted under each provision even if the total amount so designated exceeds the total amount of the RIC's dividend distributions. It also allows individual shareholders of the RIC who are U.S. persons to apply designations to the dividends they receive from the RIC that differ from designations applied by shareholders who are nonresident aliens.
Issuers of life insurance contracts that request to enter into a closing agreement with the Internal Revenue Service under Alternative B or C of Rev. Rul. 2005-6 may, in lieu of a paper submission, provide a CD-ROM diskette in read-only format listing the contracts that are the subject of the closing agreement.
This procedure provides the mechanism by which taxpayers may choose to forgo the normally required private letter ruling for switching from the fair market value method to the alternative tax book value method, within a certain limited time period. Section 864(e)(2) requires that interest expense be apportioned on the basis of assets for purposes of computing foreign source taxable income. Taxpayers may elect to compute the value of assets on the basis of fair market value or tax book value. In March 2004, Treasury and the IRS issued temporary and proposed regulations that contained a third method for determining the value of assets, the “alternative tax book value method.”
This document contains corrections to temporary regulations (T.D. 9170, 2005-4 I.R.B. 363) that provide guidance concerning the applicability of section 1374 to S corporations that acquire assets in carryover basis transactions from C corporations on or after December 27, 1994, and to certain corporations that terminate S corporation status and later elect again to become S corporations.
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