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IRB 2005-27

Table of Contents
(Dated July 5, 2005)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2005-27. 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

Rev. Rul. 2005-38

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for July 2005.

Rev. Rul. 2005-39

Golden parachute payments; treatment of section 83(b) elections. This ruling discusses whether restricted stock for which a section 83(b) election has been made is treated as outstanding stock for purposes of determining whether there has been a change in ownership or control under section 280G of the Code and for determining the amount of stock held by shareholders in testing whether the shareholder is a disqualified individual under section 280G.

Rev. Rul. 2005-40

Insurance, federal income tax purposes. This ruling considers four circumstances in which arrangements between unrelated entities do, and do not, constitute insurance for federal income tax purposes and whether the issuer qualifies as an insurance company for federal income tax purposes.

Notice 2005-48

This notice solicits applications for designation of a project as a qualified green building and sustainable design project under section 142(l) of the Code. The notice also provides guidance on the requirements a project must meet in order to be eligible for designation as a qualified green building and sustainable design project.

Notice 2005-49

This notice requests comments on the qualification of additional arrangements as insurance, including cell captive arrangements, loan-backs of amounts paid as premiums, the relevance of homogeneity in determining whether risk has been adequately distributed, and arrangements involving finite risk.

Notice 2005-50

This notice provides guidance on miscellaneous issues that have arisen in the administration of the health coverage tax credit (HCTC) under section 35 of the Code.

EMPLOYEE PLANS

REG-130241-04

Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualified plans. The proposed amendments provide comprehensive guidance regarding the limitations of section 415, including updates to the regulations for numerous statutory changes since regulations were last published. The proposed regulations also make conforming changes to regulations under sections 401(A)(9), 401(k), 403(b), and 457, and make other minor corrective changes to regulations under section 457. A public hearing is scheduled for August 17, 2005.

EXEMPT ORGANIZATIONS

Notice 2005-49

This notice requests comments on the qualification of additional arrangements as insurance, including cell captive arrangements, loan-backs of amounts paid as premiums, the relevance of homogeneity in determining whether risk has been adequately distributed, and arrangements involving finite risk.

Announcement 2005-46

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

EXCISE TAX

Notice 2005-49

This notice requests comments on the qualification of additional arrangements as insurance, including cell captive arrangements, loan-backs of amounts paid as premiums, the relevance of homogeneity in determining whether risk has been adequately distributed, and arrangements involving finite risk.

ADMINISTRATIVE

Notice 2005-48

This notice solicits applications for designation of a project as a qualified green building and sustainable design project under section 142(l) of the Code. The notice also provides guidance on the requirements a project must meet in order to be eligible for designation as a qualified green building and sustainable design project.



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