Internal Revenue Bulletin: 2005-36
September 6, 2005
Table of Contents
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 September 2005.
Mutual life insurance companies; differential earnings rate. The differential earnings rate for 2004 is determined for use by mutual life insurance companies to compute their income tax liability for 2004.
Final regulations under section 269B of the Code concern the definition and treatment of a stapled foreign corporation, which is generally treated for U.S. tax purposes as a domestic corporation. The regulations also put in regulation form Notices 89-94 and 2003-50, treating a stapled foreign corporation as foreign for purposes of determining whether it is an includible corporation within the meaning of section 1504(d), except when applying sections 1.904(i)-1 and 1.861-11T(d)(6) of the regulations.
This is the third in a series of notices, including Notice 2005-10, 2005-6 I.R.B. 474, and Notice 2005-38, 2005-22 I.R.B. 1100, providing guidance on the one time dividends received deduction (DRD) under section 965 for certain cash dividends from controlled foreign corporations that are invested in the United States. This notice provides guidance with respect to the foreign tax credit and related issues under section 965, foreign currency translation, the alternative minimum tax, and the credit for prior year minimum tax. Notice 2005-10 clarified and Notice 2005-38 modified.
Time periods for requesting consent to change a method of accounting. For a taxpayer desiring consent to change a method of accounting provided for under certain regulations, this procedure waives the requirement to request consent within the time periods prescribed in those regulations provided the taxpayer requests consent in accordance with this procedure. Rev. Proc. 83-77 superseded.
This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2003.
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