Internal Revenue Bulletin: 2011-19
May 9, 2011
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 May 2011.
Final regulations under section 904(d) of the Code provide transition rules regarding the reduction of the number of separate foreign tax credit limitation categories.
Proposed regulations under section 108(a) of the Code relate to the exclusion from gross income of discharge of indebtedness income of a grantor trust or an entity that is disregarded as an entity separate from its owner. The regulations provide rules regarding the term “taxpayer” for purposes of applying section 108 to discharge of indebtedness income of a grantor trust or a disregarded entity.
To provide a more uniform method for the federal income taxation of Treasury Inflation-Protected Securities (TIPS), this notice provides that the IRS and the Department of the Treasury plan to issue regulations that will provide that the coupon bond method described in regulations section 1.1275-7(d) applies to TIPS issued with more than a de minimis amount of premium. The regulations will be effective for TIPS issued on or after April 8, 2011.
This notice provides further guidance to Notice 2010-60 and requests comments regarding implementation of chapter 4 of the Code. Notice 2010-60 supplemented and superseded.
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