Internal Revenue Bulletin: 2004-35
August 30, 2004
Low-income housing credit. This ruling answers 12 questions about the low-income housing credit provisions under section 42 of the Code.
LIFO; price indexes; department stores. The June 2004 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, June 30, 2004.
Final regulations provide guidance under section 904(d) of the Code, including guidance relating to the exception from passive income for active rents and royalties. The regulations provide guidance under section 904(b) relating to adjustments to the foreign tax credit limitation when a taxpayer has capital gains or losses or qualified dividend income. They provide guidance for individuals who elect under section 904(j) not to apply the foreign tax credit limitation for a particular year. The regulations provide guidance on the allocation of foreign taxes to the separate categories of income under regulations section 1.904-6. Finally, the regulations provide guidance on the exclusion of certain export financing interest from foreign personal holding company income.
Optional 10-year writeoff of certain tax preferences. Proposed regulations under section 59(e) of the Code provide rules governing the time and manner for making and revoking an election to treat certain qualified expenditures, which are otherwise deductible, as amortized over the applicable period provided for in the statute. The regulations provide that the election may be made for any specific dollar amount of the qualified expenditures, but cannot be made by reference to a formula. To revoke the election, a taxpayer must receive the permission of the Commissioner. Permission will only be granted in rare and unusual circumstances. If permission is granted, the revocation will be effective in the taxpayer’s earliest open taxable year affected by the election.
This document withdraws proposed regulations (REG-104683-00, 2001-1 C.B. 407) under section 904(d) of the Code relating to the “look-through” rules for dividends paid by a controlled foreign corporation or a noncontrolled section 902 corporation. It also withdraws proposed regulations under section 902 relating to the computation of a taxpayer’s deemed-paid taxes. REG-104683-00 partially withdrawn.
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