This is the table of contents of Internal Revenue Bulletin IRB 2005-33. 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.
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.
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 August 2005.
Final regulations under section 1363(d) of the Code address LIFO recapture by corporations converting from C corporations to S corporations. The purpose of these regulations is to provide guidance on the LIFO recapture requirement when the corporation holds inventory accounted for under the last-in, first-out (LIFO) method (LIFO inventory) indirectly through a partnership.
Final regulations under section 861 of the Code provide that deductions for charitable contributions (as defined in section 170(c)) are definitely related and allocable to all of a taxpayer’s gross income and are apportioned on the basis of income from sources within the United States. In addition, regulations are finalized in this document with respect to the allocation and apportionment of deductions for charitable contributions that are provided by an income tax treaty rather than by sections 170, 873(b)(2), and 882(c)(1)(B).
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).
Profit-sharing plan; retiree health accounts; nonforfeitability; prospective application. This ruling holds that a sub-account within a profit-sharing plan that provides medical reimbursement expenses to each participant does not meet the provisions of section 411 of the Code on nonforfeitability because it imposes conditions on the use of the amounts held in the participants’ accounts. If certain criteria are met, the ruling will be applied prospectively.
Proposed regulations under section 401 of the Code provide guidance on the use of electronic media to provide certain notices to recipients or to transmit participant and beneficiary elections or consents with respect to employee benefit arrangements. A public hearing is scheduled for November 2, 2005.
This notice addresses certain income tax issues with respect to nonqualified deferred compensation plans maintained by federal credit unions, including whether a federal credit union can maintain an eligible nonqualified deferred compensation plan described in section 457 of the Code, and issues relating to plans in effect on publication of this notice that are intended to satisfy section 457.
This notice addresses certain income tax issues with respect to nonqualified deferred compensation plans maintained by federal credit unions, including whether a federal credit union can maintain an eligible nonqualified deferred compensation plan described in section 457 of the Code, and issues relating to plans in effect on publication of this notice that are intended to satisfy section 457.
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).
This document withdraws proposed regulations (REG-142686-01, 2001-2 C.B. 561) concerning the application of FICA, FUTA, and federal income tax withholding to stock options issued under an employee stock purchase plan or an incentive stock option plan (collectively, statutory stock options).
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose those penalties on reports filed with the Securities and Exchange Commission (SEC). The procedure describes the report on which the disclosures must be made, the information that must be disclosed, and the deadlines by which persons must make the disclosures on reports filed with the SEC in order to avoid additional penalties under section 6707A(e).
This document contains corrections to proposed regulations (REG-102144-04, 2005-25 I.R.B. 1297) relating to dual consolidated loss issues.
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