Reporting Rules for Widely Held Fixed Investment Trusts
These final regulations amend the reporting rules that apply to the trustees of certain investment trusts, and to the brokerage firms that hold interests as middlemen for investors in these trusts. TD 9308. Published December 29, 2006.
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Changes in Computing Deprecation
Taxpayers are required to obtain the consent of the Commissioner of Internal Revenue to change a method of accounting for federal income tax purposes. These regulations provide the changes in deprecation or amortization that are, and those changes that are not, changes in method of accounting. TD 9307. Published December 28, 2006.
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User Fees for Processing Installment Agreements
The regulations increase the amount of the user fees imposed under sections 300.1 and 300.2 for entering into and restructuring or reinstating installment agreements. The regulations bring the fees in line with the actual costs to the IRS. Currently, the IRS charges $43 for entering into an installment agreement and $24 for restructuring or reinstating an installment agreement that is in default. The IRS recently completed a review of the installment agreement program and determined that the full cost of an installment agreement is $105, and the full cost of restructuring or reinstating an installment agreement is $45. The regulations reflect these costs, with two exceptions: The fee for entering into an installment agreement will remain $43 if the taxpayer is a low-income taxpayer, and the fee for entering into an installment agreement paid by way of direct debit from the taxpayer's bank account will be $52 to encourage this type of payment arrangement. TD 9306. Published December 28, 2006.
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Source of Income from Certain Space and Ocean Activities; Source of Communications Income
These final regulations contain rules governing the source of income from certain space and ocean activities. They also contain rules governing the source of income from certain communications activities. These final regulations affect persons who derive income from activities conducted in space, or on or under water not within the jurisdiction of a foreign country, possession of the United States, or the United States (in international water). These final regulations also affect persons who derive income from transmission of communications. TD 9305. Published December 27, 2006.
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Guidance Necessary to Facilitate Business Electronic Filing Under Section 1561
These temporary regulations affect component members of controlled groups of corporations and consolidated groups filing life-nonlife Federal income tax returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type of information these members are required to submit with their returns. TD 9304. Published December 22, 2006.
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Guidance Necessary to Facilitate Business Electronic Filing Under Section 1561
The proposed regulations (which cross reference temporary regulations issued concurrently) affect component members of controlled groups of corporations and consolidated groups filing life-nonlife Federal income tax returns. They provide guidance regarding the apportionment of tax benefit items and the amount and type of information these members are required to submit with their returns.
REG-161919-05. Published December 22, 2006.
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Prohibited Allocations of Securities in an S Corporation
These final regulations contain rules under section 409(p)of the Internal Revenue Code concerning requirements for employee stock ownership plans (ESOPs) holding stock of Subchapter S corporations. The final regulations generally affect plan sponsors of, and participants in, ESOPs holding stock of Subchapter S corporations.
TD 9302. Published December 20, 2006.
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Distributions of Stock in Certain Tax-Free Reorganizations
While most tax-free reorganization provisions require one corporation that acquires another corporation to issue stock to shareholders of the corporation being acquired, the IRS has not required taxpayers to issue stock in an all cash sale of assets between two corporations when the same person or persons own the same proportion of stock in both corporations. These regulations provide guidance on when the same person or persons are treated as owning the same proportion of stock in both the acquiring and acquired corporation and therefore stock does not have to be issued in an all cash sale of assets between two corporations. TD 9303. Published December 19, 2006.
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Distributions of Stock in Certain Tax-Free Reorganizations
While most tax-free reorganization provisions require one corporation that acquires another corporation to issue stock to shareholders of the corporation being acquired, the IRS has not required taxpayers to issue stock in an all cash sale of assets between two corporations when the same person or persons own the same proportion of stock in both corporations. These regulations provide guidance on when the same person or persons are treated as owning the same proportion of in both the acquiring and acquired corporation and therefore stock does not have to be issued in an all cash sale of assets between two corporations.
REG-125632-06. Published December 19, 2006.
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Exception to the HIPAA Nondiscrimination Requirements for Certain Grandfathered Church Plans
These regulations provide guidance on the nondiscrimination requirements for group health plans under section 9802 of the Internal Revenue Code. The regulations also provide guidance on a limited exception for programs of health promotion or disease prevention. The regulations will affect plans, the employer and unions that sponsor them, and the individuals participating in them.
TD 9299. Published December 13, 2006.
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Final Rules for Nondiscrimination and Wellness Program in Health Coverage in the Group Market
These regulations provide guidance on the limited exception for certain grandfathered church plans to the nondiscrimination requirements for group health plans under section 9802 of the Internal Revenue Code. The regulations will affect some non-profit organizations and the individuals participating in health plans they sponsor.
TD 9298. Published December 13, 2006.
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Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals
These temporary regulations provide rules relating to the $500 reduction in taxable income for taxpayers who provide housing to a Hurricane Katrina displaced individual in their homes for 60 consecutive days free of charge. The regulations provide limits on the reduction and define who is a Hurricane Katrina displaced individual and what is considered providing housing. TD 9301. Published December 12, 2006.
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Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals
These proposed regulations provide rules relating to the $500 reduction in taxable income for taxpayers who provide housing to a Hurricane Katrina displaced individual in their homes for 60 consecutive days free of charge. The regulations provide limits on the reduction and define who is a Hurricane Katrina displaced individual and what is considered providing housing. REG-152043-05. Published December 12, 2006.
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Guidance Necessary to Facilitate Business Electronic Filing
These final regulations eliminate regulatory obstacles to the electronic filing of certain business income tax returns and other forms. Requiring signatures on attachments to tax return, for example, can impede a taxpayer's ability to file the return electronically. To address this problem, the final regulations provide that in a number of situations, the signature on a taxpayer's return covers attachments to that return.
TD 9300. Published December 8, 2006.
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