Internal Revenue Bulletin:  2010-45 

November 8, 2010 

INCOME TAX


T.D. 9498 T.D. 9498

Temporary and proposed regulations under section 108 of the Code provide rules regarding partnerships and S corporations. Section 108(i) allows a taxpayer to defer discharge of indebtedness income (and in certain cases, deductions for original issue discount) arising from a reacquisition of an applicable debt instrument that occurs in 2009 or 2010 for a four or five taxable-year period (unless an acceleration event occurs earlier). Once the deferral period ends, taxpayers take into account the deferred income and deductions ratably over a five taxable-year period.

REG-144762-09 REG-144762-09

Temporary and proposed regulations under section 108 of the Code provide rules regarding partnerships and S corporations. Section 108(i) allows a taxpayer to defer discharge of indebtedness income (and in certain cases, deductions for original issue discount) arising from a reacquisition of an applicable debt instrument that occurs in 2009 or 2010 for a four or five taxable-year period (unless an acceleration event occurs earlier). Once the deferral period ends, taxpayers take into account the deferred income and deductions ratably over a five taxable-year period.

T.D. 9499 T.D. 9499

Final regulations under section 6411 of the Code amend existing regulations relating to the computation and allowance of the tentative carryback adjustments.

REG-119921-09 REG-119921-09

Proposed regulations under section 7701 of the Code provide whether or not a series of a domestic series LLC, a cell of a domestic cell company, or a foreign series or cell that conducts an insurance business is a juridical person for local law purposes, for Federal tax purposes it is treated as an entity formed under local law. Classification of a series or cell that is treated as a separate entity for Federal tax purposes generally is determined under the same rules that govern the classification of other types of separate entities.


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