Internal Revenue Bulletin:  2008-46 

November 17, 2008 

INCOME TAX


T.D. 9416 T.D. 9416

Final, temporary, and proposed regulations under section 901 of the Code provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. The regulations affect taxpayers that claim direct and indirect foreign tax credits. A public hearing on the proposed regulations is scheduled for December 11, 2008.

REG-156779-06 REG-156779-06

Final, temporary, and proposed regulations under section 901 of the Code provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. The regulations affect taxpayers that claim direct and indirect foreign tax credits. A public hearing on the proposed regulations is scheduled for December 11, 2008.

REG-164370-05 REG-164370-05

Proposed regulations under section 108(e)(8) of the Code provide guidance in determining the discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership’s indebtedness. In particular, the regulations address how the fair market value of a partnership interest transferred by the debtor partnership to the creditor in satisfaction of the partnership’s indebtedness is determined. The regulations also provide that section 721 generally applies to a contribution of a partnership’s indebtedness by a creditor to the partnership in exchange for an interest in the partnership. A public hearing is scheduled for February 19, 2009.


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