Final, temporary, and proposed regulations under section 954 of the Code contain rules for determining whether a controlled foreign corporation's (CFC's) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception). These regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs.
Final regulations under section 671 of the Code define widely held fixed investment trusts, clarify the reporting obligations of he trustees and the middlemen connected with these trusts, and provide for communication of tax information to beneficial owners of trust interests.
Final regulations under section 368 of the Code define the term statutory merger or consolidation as used in the Internal Revenue Code. The regulations remove the requirement in temporary regulations that transactions must be carried out under domestic law in order to qualify as a statutory merger or consolidation. The regulations also provide that a transaction may qualify even if it involves foreign entities. They also provide a special rule that addresses the qualification as a statutory merger or consolidation of a transaction involving certain entities that are disregarded as entities separate from their corporate owners for federal income tax purposes.
Flo-Ro Management of Florissant, MO, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.
The Service is suspending certain requirements under section 42 of the Code for low-income housing credit projects in the United States as a result of the devastation caused by Hurricane Rita.
This notice supplements the relief previously granted by the IRS with respect to taxpayers affected by Hurricanes Katrina and Rita. It provides relief from certain backup withholding obligations under section 3406 of the Code due to notification that a payee's taxpayer identification number is incorrect. Pursuant to the authority of section 7508A, the IRS postpones the time for certain payors to send notices to payees, and to begin imposing backup withholding on reportable payments to such payees.
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