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IRB 2005-18

Table of Contents
(Dated May 2, 2005)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2005-18. 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.

INCOME TAX

Health Savings Accounts (HSAs); non-high deductible health plan (HDHP). This ruling provides guidance on eligibility and contribution rules under section 223 of the Code for a married individual whose spouse has non-high deductible health plan (HDHP) coverage. A married individual may contribute to a Health Savings Account (HSA) even though his or her spouse has non-HDHP coverage, so long as the individual is not covered by the spouse’s non-HDHP. The maximum amount that an eligible individual may contribute to an HSA is based on whether the individual has self-only or family HDHP coverage.

Final, temporary, and proposed regulations under section 7701 of the Code add to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. A public hearing on the proposed regulations is scheduled for July 27, 2005.

Final, temporary, and proposed regulations under section 7701 of the Code add to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. A public hearing on the proposed regulations is scheduled for July 27, 2005.

Final regulations under section 355(e) of the Code relate to the recognition of gain on certain distributions of stock or securities in connection with an acquisition. The regulations provide guidance on whether an acquisition and a distribution are part of a plan (or series of related transactions).

This procedure describes how a regulated investment company (RIC) that holds a partnership interest is treated. A RIC that is a consenting partner in a partnership, that has in effect a monthly closing election under Rev. Proc. 2003-84, 2003-2 C.B. 1159, is treated as if directly invested in the assets held by the partnership. Rev. Proc. 2003-32 amplified and superseded.

This document contains corrections to final regulations (T.D. 9165, 2005-4 I.R.B. 357) under section 330 of Title 31 of the U.S. Code governing practice before the Internal Revenue Service (Circular 230).

EMPLOYEE PLANS

Retroactive payment of benefits; remedial amendment period; determination letters. This document contains procedures to limit the retroactive application of the decision in Central Laborers’ Pension Fund v. Heinz, 124 S.Ct. 2230 (2004), for affected retirement plans qualified under section 401(a) of the Code.

TAX CONVENTIONS

Mutual Agreement on U.K. pension arrangements. A copy of the news release issued by the Director, International (U.S. Competent Authority), on April 13, 2005 (IR-2005-44), is set forth.

ADMINISTRATIVE

Final, temporary, and proposed regulations under section 7701 of the Code add to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. A public hearing on the proposed regulations is scheduled for July 27, 2005.

Final, temporary, and proposed regulations under section 7701 of the Code add to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. A public hearing on the proposed regulations is scheduled for July 27, 2005.

This procedure describes how a regulated investment company (RIC) that holds a partnership interest is treated. A RIC that is a consenting partner in a partnership, that has in effect a monthly closing election under Rev. Proc. 2003-84, 2003-2 C.B. 1159, is treated as if directly invested in the assets held by the partnership. Rev. Proc. 2003-32 amplified and superseded.



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