Internal Revenue Bulletin: 2009-6 |
February 9, 2009 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
- Rev. Rul. 2009-5
- T.D. 9442
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Background
- Explanation of Provisions
- Former Regulations Under §1.1502-13(g) (the Former Regulations)
- Significant Changes Made by the 2007 Proposed Regulations
- General Comments
- A. Anti-Abuse Rules
- B. Deemed Satisfaction and Reissuance for Fair Market Value
- C. Exceptions and Related Provisions
- 1. Overlap of Exceptions and Deemed Exchanges under §1.1001-3
- 2. Exception for Intercompany Taxable Assumption Transactions
- 3. Intercompany Nonrecognition Exchange Exceptions
- a. Section 351 Exception
- b. Scope of Exception under Section 332
- c. Gain or Loss With Respect to an Intercompany Obligation
- 4. Outbound Exception for Intercompany Obligations Newly-Issued in a Reorganization
- 5. Exceptions to the Application of Section 108(e)(4)
- Special Analyses
- Adoption of Amendments to the Regulations
- Drafting Information
- Part III. Administrative, Procedural, and Miscellaneous
- Notice 2009-12
- Notice 2009-13
- Notice 2009-15
- Rev. Proc. 2009-16
- SECTION 1. PURPOSE
- SECTION 2. BACKGROUND
- SECTION 3. TIME AND MANNER FOR MAKING THE § 168(k)(4) ELECTION
- SECTION 4. ALLOCATION OF THE BONUS DEPRECIATION AMOUNT
- SECTION 5. PARTNERSHIPS WITH CORPORATE PARTNERS THAT MAKE THE § 168(k)(4) ELECTION
- SECTION 6. APPLICATION OF § 168(k)(4) TO S CORPORATIONS AND THEIR SHAREHOLDERS
- SECTION 7. APPLICATION OF § 3081(b) OF THE HOUSING ACT
- SECTION 8. EFFECT ON OTHER DOCUMENTS
- SECTION 9. PAPERWORK REDUCTION ACT
- SECTION 10. EFFECTIVE DATE
- SECTION 11. DRAFTING INFORMATION
- Part IV. Items of General Interest
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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