Internal Revenue Bulletin: 2011-51
December 19, 2011
Final regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax and make conforming amendments under sections 6111 and 6112. The regulations provide guidance under section 6112 regarding the length of time a material advisor has to prepare the list that must be maintained after the list maintenance requirement first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements.
Proposed regulations will amend regulations section 20.2032-1 to provide guidance that clarifies for the executor of an estate that elects to use the alternate valuation method under section 2032 of the Code what constitutes a distribution, sale, exchange, or other disposition and what post-death occurrences the executor may consider when valuing property includible in the gross estate on the alternate valuation date. A public hearing is scheduled for March 9, 2012.
This announcement informs bankruptcy trustees (or debtors-in-possession) of a change of address for the Centralized Insolvency Operation that should be used for the submission of requests for tax refunds under section 505(a) of the Bankruptcy Code or requests for prompt determinations of any unpaid tax liability of the estate incurred during the bankruptcy case under section 505(b) of the Bankruptcy Code. Rev. Procs. 2010-27 and 2006-24 modified.
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