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IRB 2005-40

Table of Contents
(Dated October 3, 2005)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2005-40. 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

This announcement informs issuers of tax-exempt bonds that the Service will immediately put into effect procedures to provide relief to issuers affected by Hurricane Katrina. Affected issuers are provided additional time to file forms required under section 149(e) of the Code and to make payments required under section 149(f). In addition, affected issuers may also be granted other relief under appropriate circumstances.

INCOME TAX

Final regulations under section 951 of the Code prescribe rules under which a United States shareholder of a controlled foreign corporation (CFC) determines its pro rata share of the subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations.

Proposed regulations under section 482 of the Code provide guidance with respect to the sharing of costs and risks under cost sharing arrangements. They replace the existing guidance under regulations section 1.482-7 to provide clarification and additional guidance regarding the scope and valuation of the external inputs for which arm’s length consideration must be provided as an entry condition into cost sharing (“buy-ins” under the current regulations), as well as to address other technical and procedural issues that have arisen in the course of the administration of the cost sharing rules. A public hearing is scheduled for November 16, 2005.

Proposed regulations under section 951 of the Code prescribe rules under which a United States shareholder of a controlled foreign corporation (CFC) determines its pro rata share of the subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base company shipping operations, when a CFC’s earnings and profits for a taxable year substantially exceed its net income under United States generally accepted accounting principles (US GAAP).

EMPLOYEE PLANS

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for September 2005 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth.

Hurricane Katrina; hardship distributions; loans. This announcement describes certain broad-based relief from the Service, the Department of the Treasury, and the Department of Labor to retirement plan participants affected by Hurricane Katrina.

EXEMPT ORGANIZATIONS

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

ADMINISTRATIVE

This notice postpones the deadlines for certain acts under section 7508A of the Code performed by the IRS with respect to certain taxpayers affected by Hurricane Katrina.

Leave-based donation programs. This notice provides guidance to employers and employees regarding employer sponsored leave-based donation programs under which employees elect to forgo vacation, sick, or personal leave in exchange for cash payments the employer makes to organizations described in section 170(c) of the Code for the relief of victims of Hurricane Katrina.

The Service is suspending certain requirements under section 42 of the Code for low-income housing credit projects in the United States as a result of the devastation caused by Hurricane Katrina.

This announcement informs issuers of tax-exempt bonds that the Service will immediately put into effect procedures to provide relief to issuers affected by Hurricane Katrina. Affected issuers are provided additional time to file forms required under section 149(e) of the Code and to make payments required under section 149(f). In addition, affected issuers may also be granted other relief under appropriate circumstances.



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