Internal Revenue Bulletin: 2005-27
July 5, 2005
Table of Contents
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for July 2005.
Golden parachute payments; treatment of section 83(b) elections. This ruling discusses whether restricted stock for which a section 83(b) election has been made is treated as outstanding stock for purposes of determining whether there has been a change in ownership or control under section 280G of the Code and for determining the amount of stock held by shareholders in testing whether the shareholder is a disqualified individual under section 280G.
Insurance, federal income tax purposes. This ruling considers four circumstances in which arrangements between unrelated entities do, and do not, constitute insurance for federal income tax purposes and whether the issuer qualifies as an insurance company for federal income tax purposes.
This notice solicits applications for designation of a project as a qualified green building and sustainable design project under section 142(l) of the Code. The notice also provides guidance on the requirements a project must meet in order to be eligible for designation as a qualified green building and sustainable design project.
This notice requests comments on the qualification of additional arrangements as insurance, including cell captive arrangements, loan-backs of amounts paid as premiums, the relevance of homogeneity in determining whether risk has been adequately distributed, and arrangements involving finite risk.
This notice provides guidance on miscellaneous issues that have arisen in the administration of the health coverage tax credit (HCTC) under section 35 of the Code.
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