Internal Revenue Bulletin: 2010-45 |
November 8, 2010 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
- T.D. 9498
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation of Provisions
- A. Applicable Debt Instrument
- B. Allocation of COD Income
- C. Basis Adjustments
- D. Deferred Section 752 Amount Rules
- E. Capital Accounts
- F. Section 465(e) Recapture
- G. Deferral of Original Issue Discount
- H. Acceleration Events
- I. Foreign Partners of Electing Partnership
- J. Effective Date
- Availability of IRS documents
- Special Analyses
- Amendments to the Regulations
- Drafting Information
- Rev. Rul. 2010-27
- T.D. 9499
- T.D. 9498
- Part IV. Items of General Interest
- REG-119921-09
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- ADDRESSES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Background
- 1. Introduction
- 2. Entity Classification for Federal Tax Purposes
- A. Regulatory framework
- B. Separate entity classification
- C. Insurance company classification
- 3. Overview of Series LLC Statutes and Cell Company Statutes
- A. Domestic statutes
- B. Statutes with respect to insurance
- Explanation of Provisions
- 1. In General
- 2. Classification of a Series that is Treated as a Separate Entity for Federal Tax Purposes
- 3. Entity Status of Series Organizations
- 4. Continuing Applicability of Tax Law Authority to Series
- 5. Applicability to Organizations that Qualify as Insurance Companies
- 6. Effect of Local Law Classification on Tax Collection
- 7. Employment Tax and Employee Benefits Issues
- A. In general
- B. Employment tax
- C. Employee benefits
- 8. Statement Containing Identifying Information about Series
- Proposed Effective Date
- Special Analyses
- Comments and Requests for a Public Hearing
- Proposed Amendments to the Regulations
- Drafting Information
- REG-144762-09
- Announcement 2010-80
- Announcement 2010-81
- REG-119921-09
- 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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