Internal Revenue Bulletin: 2011-48
November 28, 2011
Table of Contents
Geographical areas included in North American area. This ruling contains an updated list of all geographical areas included in the North American area for purposes of section 274 of the Code. Rev. Rul. 2007-28 superseded.
Section 1274A - inflation adjusted numbers for 2012. This ruling provides the dollar amounts, increased by the 2012 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2010-30 supplemented and superseded.
Proposed regulations under section 892 of the Code relate to the taxation of certain investment income earned by foreign governments in the United States.
Proposed regulations under section 964 of the Code clarify and add examples illustrating the application of final regulations relating to the procedures for U.S. shareholders of foreign corporations to make tax accounting elections on behalf of the foreign corporations for purposes of computing the foreign corporation’s earnings and profits for U.S. tax purposes. The regulations also update the rules relating to required book-to-tax adjustments in respect of depreciation and amortization and contain a rule related to mandated changes in methods of accounting in connection with an audit or audits of a foreign corporation’s controlling domestic shareholders.
This announcement notifies taxpayers that the Service has withdrawn Weld Rite, Inc.’s right to certify its hydronic outdoor wood-burning furnaces. Therefore, this announcement also notifies taxpayers that they may no longer rely on Weld Rite, Inc.’s certification statement to claim a section 25C credit for the furnaces.
This document contains a withdrawal of proposed regulations (REG-158677-05, 2007-1 C.B. 975) clarifying that if a bank is an S corporation within the meaning of section 1361(a)(1) of the Code, its status as an S corporation does not affect the applicability of the special rules for banks under the Internal Revenue Code.
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