Internal Revenue Bulletin:  2009-43 

October 26, 2009 

INCOME TAX


T.D. 9458 T.D. 9458

Temporary and proposed regulations under section 1502 of the Code provide for an election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. Pursuant to the election, the liquidation and recontribution will be recharacterized as a cross-chain reorganization, rather than a liquidation or an upstream reorganization followed by a drop of assets.

REG-139068-08 REG-139068-08

Temporary and proposed regulations under section 1502 of the Code provide for an election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. Pursuant to the election, the liquidation and recontribution will be recharacterized as a cross-chain reorganization, rather than a liquidation or an upstream reorganization followed by a drop of assets.

T.D. 9465 T.D. 9465

Final regulations under section 882 of the Code provide guidance on interest allocation for foreign corporations to coordinate with recent income tax treaties; provide guidance on the adoption of a fixed ratio election and a 30-day published LIBOR rate election in the allocation formula; modify the liability reduction election under the branch profits tax; and make miscellaneous technical corrections and clarifications.

T.D. 9466 T.D. 9466

Final, temporary, and proposed regulations under sections 6229(c)(2) and 6501(e) of the Code define an omission from gross income for purposes of the six-year minimum period for assessment of tax attributable to partnership items and the six-year period for assessing tax.

REG-108045-08 REG-108045-08

Final, temporary, and proposed regulations under sections 6229(c)(2) and 6501(e) of the Code define an omission from gross income for purposes of the six-year minimum period for assessment of tax attributable to partnership items and the six-year period for assessing tax.

REG-140492-02 REG-140492-02

This document contains a withdrawal of proposed regulations (REG-140492-02, 2004-1 C.B. 1031) under section 142(a)(6) of the Code, which defined solid waste disposal facilities. This document also reissues the withdrawn proposed regulations and updates the definition of solid waste disposal facilities for purposes of section 142(a)(6). Generally, interest on a state or local bond is excluded from gross income. However, the exclusion does not apply to a private activity bond unless the bond is a qualified bond. A qualified bond includes an exempt facility bond that meets certain requirements. Exempt facility bonds include bonds for solid waste disposal facilities. The proposed regulations define solid waste disposal facilities for purposes of exempt facility bonds. A public hearing is scheduled for January 5, 2010.


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