Internal Revenue Bulletin: 2006-33
August 14, 2006
Final regulations under section 338 of the Code provide that the step transaction doctrine will not be applied if a taxpayer makes a valid section 338(h)(10) election with respect to a step in a multi-step transaction, even if the transaction would otherwise qualify as a reorganization if the step standing alone is a qualified stock purchase.
Final regulations under section 4980G of the Code provide guidance regarding employer comparable contributions to Health Savings Accounts (HSAs). The regulations provide that if an employer makes comparable contributions to any employee’s HSA, the employer must make comparable contributions for the calendar year to the HSAs of all comparable participating employees. In addition, the final regulations set forth the rules for calculating comparable contributions.
This notice provides guidance with respect to the 50-percent additional first year depreciation deduction provided by section 1400N(d) of the Code for qualified Gulf Opportunity (GO) Zone property. Rev. Proc. 2002-9 modified and amplified.
This notice states that the Treasury Department and IRS intend to amend the effective date provision of regulations section 1.7874-2T (and when it is finalized, 1.7874-2) so that it will not apply to certain acquisitions, otherwise described in section 7874(a)(2)(b)(i) of the Code which were completed on or after June 6, 2006, provided such acquisitions were entered into pursuant to a binding commitment which was in effect on December 28, 2005.
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