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IRB 2005-36

Table of Contents
(Dated September 6, 2005)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2005-36. 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

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 September 2005.

Mutual life insurance companies; differential earnings rate. The differential earnings rate for 2004 is determined for use by mutual life insurance companies to compute their income tax liability for 2004.

Final regulations under section 269B of the Code concern the definition and treatment of a stapled foreign corporation, which is generally treated for U.S. tax purposes as a domestic corporation. The regulations also put in regulation form Notices 89-94 and 2003-50, treating a stapled foreign corporation as foreign for purposes of determining whether it is an includible corporation within the meaning of section 1504(d), except when applying sections 1.904(i)-1 and 1.861-11T(d)(6) of the regulations.

This is the third in a series of notices, including Notice 2005-10, 2005-6 I.R.B. 474, and Notice 2005-38, 2005-22 I.R.B. 1100, providing guidance on the one time dividends received deduction (DRD) under section 965 for certain cash dividends from controlled foreign corporations that are invested in the United States. This notice provides guidance with respect to the foreign tax credit and related issues under section 965, foreign currency translation, the alternative minimum tax, and the credit for prior year minimum tax. Notice 2005-10 clarified and Notice 2005-38 modified.

Time periods for requesting consent to change a method of accounting. For a taxpayer desiring consent to change a method of accounting provided for under certain regulations, this procedure waives the requirement to request consent within the time periods prescribed in those regulations provided the taxpayer requests consent in accordance with this procedure. Rev. Proc. 83-77 superseded.

This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2003.

ADMINISTRATIVE

Temporary and proposed regulations under section 6020 of the Code modify the provisions of the current regulations section 301.6020-1 to provide the following: (1) a document (or set of documents) signed by the Commissioner or other authorized Internal Revenue officer or employee shall be a return under section 6020(b) if the document (or set of documents) identifies the taxpayer by name and taxpayer identification number, contains sufficient information from which to compute the taxpayer’s tax liability, and the document (or set of documents) purports to be a return; (2) the document and subscription may be in written or electronic form; and (3) pursuant to section 6651(g)(2), the document that constitutes a return under section 6020(b) will be treated as the return filed by the taxpayer for purposes of determining the amount of the addition to tax under sections 6651(a)(2) and (a)(3).

Temporary and proposed regulations under section 6020 of the Code modify the provisions of the current regulations section 301.6020-1 to provide the following: (1) a document (or set of documents) signed by the Commissioner or other authorized Internal Revenue officer or employee shall be a return under section 6020(b) if the document (or set of documents) identifies the taxpayer by name and taxpayer identification number, contains sufficient information from which to compute the taxpayer’s tax liability, and the document (or set of documents) purports to be a return; (2) the document and subscription may be in written or electronic form; and (3) pursuant to section 6651(g)(2), the document that constitutes a return under section 6020(b) will be treated as the return filed by the taxpayer for purposes of determining the amount of the addition to tax under sections 6651(a)(2) and (a)(3).

This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2003.

This document contains a correction to Announcement 2005-53, 2005-31 I.R.B. 258, which corrected T.D. 9186 relating to qualified amended returns.

This document contains corrections to T.D. 9193, 2005-15 I.R.B. 862, by adding the text that was inadvertently omitted from the Code of Federal Regulations. The regulations relate to the tax treatment of installment obligations and property acquired pursuant to a contract.

This document contains corrections to temporary regulations (T.D. 9205, 2005-25 I.R.B. 1267) relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control.



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