Internal Revenue Bulletin: 2010-44 |
November 1, 2010 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
- T.D. 9497
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation of Provisions
- I. Mandatory Acceleration Events for Deferred COD Income
- A. Net value acceleration rule
- 1. Consolidated Groups
- 2. Exception for Distributions and Charitable Contributions Consistent with Historical Practice — In General
- 3. Special Rules for Regulated Investment Companies (RICs) and Real Estate Investment Trusts (REITs)
- B. Other mandatory acceleration events
- 1. Changes in Tax Status
- 2. Cessation of Existence
- a. Outbound section 381(a) transactions
- b. Inbound section 381(a) transactions
- c. Acquisition of assets of an electing corporation by a RIC or REIT or by an S corporation
- C. Title 11 (or similar case)
- II. Elective Acceleration for Electing Members of a Consolidated Group
- III. Earnings and Profits
- IV. Deferred OID Deductions
- A. Application of §1.1502-13(g)(5)
- B. Deemed debt-for-debt exchanges
- C. Directly or indirectly
- D. Proportional rule for accruals of OID
- E. Acceleration events for deferred OID deductions
- V. Effective/Applicability Dates
- Comments
- Special Analyses
- Amendments to the Regulations
- Drafting Information
- Rev. Rul. 2010-25
- Rev. Rul. 2010-26
- T.D. 9497
- Part III. Administrative, Procedural, and Miscellaneous
- Part IV. Items of General Interest
- REG-142800-09
- REG-138637-07
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation of Provisions
- Definitions — Practice Before the Internal Revenue Service and Tax Return Preparer
- Who May Practice
- Eligibility to Become a Registered Tax Return Preparer
- Application and Renewal Procedures
- Continuing Education Providers
- Limited Practice Before the IRS, Return Preparation, and Application to Other Individuals
- Solicitation
- Standards With Respect to Tax Returns and Documents, Affidavits and Other Papers
- Procedures to Ensure Compliance
- Incompetence and Disreputable Conduct
- Records
- Proposed Effective Date
- Special Analyses
- A. Regulatory Assessment under E.O. 12866
- 1. Description of need for the regulatory action
- 2. Potentially affected tax returns
- 3. An assessment of benefits anticipated from the regulatory action
- 4. An assessment of costs anticipated from the regulatory action
- 5. An assessment of costs and benefits of potential alternatives
- i. Baseline scenario
- ii. Alternative one
- iii. Alternative two
- iv. Alternative three
- B. Initial Regulatory Flexibility Analysis
- 1. Description of the reasons why the agency action is being considered
- 2. Statement of the objectives of, and legal basis for, the proposed rule
- 3. Description and estimate (where feasible) of the number of small entities subject to the proposed rule
- 4. Description of the projected reporting, recordkeeping and related requirements of the proposed rule, including an estimate of the classes of small entities that will be subject to the requirements and the type of professional skills necessary for preparation of the report or record
- 5. Identification, to the extent practicable, of all relevant Federal rules that may duplicate, overlap or conflict with the proposed rule
- 6. Description of any significant alternatives to the proposed rule that accomplish the stated objectives of applicable statutes and which minimize any significant economic impact on small entities
- Comments and Requests For Public Hearing
- Drafting Information
- Withdrawal of Notice of Proposed Rulemaking
- Proposed Amendments to the Regulations
- PART 10—PRACTICE BEFORE THE INTERNAL
REVENUE SERVICE
- §10.0 Scope of part.
- §10.2 Definitions.
- §10.3 Who may practice.
- §10.4 Eligibility to become an enrolled agent, enrolled retirement plan agent, or registered tax return preparer.
- §10.5 Application to become an enrolled agent, enrolled retirement plan agent, or registered tax return preparer.
- §10.6 Term and renewal of status as an enrolled agent, enrolled retirement plan agent, or registered tax return preparer.
- §10.7 Representing oneself; participating in rulemaking; limited practice; and special appearances.
- §10.8 Return preparation and application of rules to other individuals.
- §10.9 Continuing education programs.
- §10.30 Solicitation.
- §10.34 Standards with respect to tax returns and documents, affidavits and other papers.
- §10.36 Procedures to ensure compliance.
- §10.51 Incompetence and disreputable conduct.
- §10.90 Records.
- Announcement 2010-84
- Announcement 2010-85
- Announcement 2010-86
- 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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