This document contains the annual report to the public concerning
Advance Pricing Agreements (APAs) and the experience
of the APA program during calendar year 2005. This
document does not provide guidance regarding the application
of the arm's length standard. Instead, it reports on the structure
and activities of the APA program.
This notice provides relief for persons who have rehabilitation
credit property in areas affected by Hurricanes Katrina, Rita,
or Wilma. First, the notice provides a safe harbor period of
three years for repair of rehabilitation credit property placed
in service prior to the hurricanes and damaged by the hurricanes
during which time the property is not subject to rehabilitation
credit recapture under Code section 50(a)(1) provided
that repairs to the property are actively ongoing. Second, for
property on which the rehabilitation had begun but has not yet
been placed in service on the date that the President declared
a major disaster in the area in which the property is located,
the running of the 24-month or 60-month period is tolled for a
period of 12 months.
Final regulations under section 417 of the Code concern content
requirements applicable to explanations of qualified joint
and survivor annuities and qualified preretirement survivor annuities
payable under certain retirement plans.
Consumer Guidance Corp., of Sun Valley, CA, and Next Step
Foundation, Inc., of Little Rock, AR, no longer qualify as organizations
to which contributions are deductible under section
170 of the Code.
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