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IRB 2004-43

Table of Contents
(Dated October 25, 2004)
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This is the table of contents of Internal Revenue Bulletin IRB 2004-43. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

SPECIAL ANNOUNCEMENT

The Seventeenth Annual Institute on Current Issues in International Taxation, jointly sponsored by the Internal Revenue Service and The George Washington University Law School, will be held on December 9 and 10, 2004, at the J. W. Marriott Hotel in Washington, DC.

INCOME TAX

Final regulations under section 6038A of the Code amend existing regulations to provide that a Form 5472 that is timely filed electronically is treated as satisfying the requirement of timely filing a duplicate Form 5472 with the Internal Revenue Service Center in Philadelphia, Pennsylvania. The regulations affect corporations subject to the reporting requirements in sections 6038A and 6038C that file Form 5472 electronically.

This procedure allocates the national limitation of $400 million for year 2004 for Qualified Zone Academy Bonds (QZABs) among the states (“states” includes the District of Columbia and possessions of the U.S. (American Samoa, Northern Marianas, Puerto Rico, Guam, and the Virgin Islands)). The procedure implements the amendments to section 1397E(e)(1) of the Code made by section 304 of the Working Families Tax Relief Act of 2004, which extended the authority to issue QZABs in the amount of $400 million each for years 2004 and 2005.

EMPLOYEE PLANS

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for October 2004 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth.

EXEMPT ORGANIZATIONS

A list is provided of organizations now classified as private foundations.

ADMINISTRATIVE

Proposed regulations under section 7502 of the Code amend regulations section 301.7502-1 to provide that, other than direct proof of actual delivery, a registered or certified mail receipt is the only prima facie evidence of delivery of documents that have a filing deadline prescribed by the internal revenue laws. The regulations are necessary to provide greater certainty on this issue and to provide specific guidance. The regulations affect taxpayers who mail federal tax documents to the Internal Revenue Service or the United States Tax Court.

This notice announces that the IRS and Treasury will amend regulations section 301.7701-2(b)(8) to include certain foreign entities on the list of entities always treated as corporations under section 7701 of the Code.

This procedure allocates the national limitation of $400 million for year 2004 for Qualified Zone Academy Bonds (QZABs) among the states (“states” includes the District of Columbia and possessions of the U.S. (American Samoa, Northern Marianas, Puerto Rico, Guam, and the Virgin Islands)). The procedure implements the amendments to section 1397E(e)(1) of the Code made by section 304 of the Working Families Tax Relief Act of 2004, which extended the authority to issue QZABs in the amount of $400 million each for years 2004 and 2005.

Recently passed legislation has restored the filing requirement for Forms 8851, Summary of Archer MSAs, for tax year 2004. This announcement details changes to Revenue Procedure 2001-31, which details the format and filing requirements for filing Form 8851, electronically or magnetically.



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