Internal Revenue Bulletin:  2005-23 

June 6, 2005 

INCOME TAX


Rev. Rul. 2005-32 Rev. Rul. 2005-32

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 June 2005.

Rev. Rul. 2005-33 Rev. Rul. 2005-33

Insurance companies; premium stabilization reserves. This ruling holds that additions to premium stabilization reserves are return premiums for purposes of determining the amount of premiums earned on insurance contracts during a taxable year.

T.D. 9200 T.D. 9200

Final, temporary, and proposed regulations under section 1446 of the Code provide guidance on the withholding tax liability of a partnership with income that is effectively connected with its U.S. trade or business, all or a portion of which is allocable under section 704 to foreign partners. The regulations also provide rules permitting a partnership under certain circumstances to consider partner-level deductions and losses when computing its section 1446 withholding tax obligation with respect to a foreign partner. A public hearing on the proposed regulations is scheduled for October 3, 2005.

REG-108524-00 REG-108524-00

Final, temporary, and proposed regulations under section 1446 of the Code provide guidance on the withholding tax liability of a partnership with income that is effectively connected with its U.S. trade or business, all or a portion of which is allocable under section 704 to foreign partners. The regulations also provide rules permitting a partnership under certain circumstances to consider partner-level deductions and losses when computing its section 1446 withholding tax obligation with respect to a foreign partner. A public hearing on the proposed regulations is scheduled for October 3, 2005.

Notice 2005-41 Notice 2005-41

Charitable contributions; qualified intellectual property. This notice explains how amendments to section 170 of the Code made by the American Jobs Creation Act of 2004 limit the initial charitable contribution deduction allowable to a donor of qualified intellectual property. The notice also provides guidance on how, under the amendments, the donor may qualify for additional charitable contribution deductions based on the income received by or accrued to the donee organization with respect to the donated property.

Notice 2005-42 Notice 2005-42

This notice allows employers sponsoring cafeteria plans the option to amend the cafeteria plan document to provide a grace period after the end of the plan year, during which unused benefits or contributions remaining at the end of the immediately preceding plan year may be paid or reimbursed to participants for qualified benefit expenses incurred during the grace period. The grace period must not extend beyond the fifteenth day of the third calendar month following the end of the immediately preceding plan year.


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