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IRB 2005-52

Table of Contents
(Dated December 27, 2005)
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This is the table of contents of Internal Revenue Bulletin IRB 2005-52. 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

LIFO; price indexes; department stores. The October 2005 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, October 31, 2005.

This notice contains a proposed revenue procedure that would provide guidance to tax return preparers regarding the format and content of consents to use and consents to disclose tax return information under proposed section 301.7216-3 of the regulations, which was filed with the Federal Register contemporaneously with the public release of this notice on December 7, 2005. The proposed revenue procedure would also provide specific requirements for electronic signatures when a taxpayer executes an electronic consent to the use or disclosure of the taxpayer’s tax return information.

This notice requests comments on possible changes to Rev. Proc. 2002-9, which provides the procedures for taxpayers to request automatic consent from the Commissioner to change to certain methods of accounting.

This notice solicits applications for allocations of the clean renewable energy bond limitation under section 54(f) of the Code and provides guidance with respect to the issuance and post issuance compliance of clean renewable energy bonds.

Regulations section 1.482-7(d)(2)(iii)(B) provides an elective method whereby controlled participants of a qualified cost sharing arrangement (QCSA) may take into account the cost of certain stock-option compensation in the same amount, and as of the same time, as the fair value of the stock options reflected as a charge against income in certain audited financial statements or disclosed in footnotes to such statements. This notice extends this elective method to certain restricted shares and restricted share units. It also permits taxpayers employing the elective method to choose to determine whether stock-based compensation is related to the intangible development area by analyzing the activities of the employee recipients of the stock-based compensation by reference to financial reporting periods, identifying the related compensation on a period by period basis.

EMPLOYEE PLANS

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

Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regulatory, and guidance changes needed for certain requests to the Service.

EMPLOYMENT TAX

This notice suspends employers’ and payers’ reporting and wage withholding requirements with respect to deferrals of compensation under section 409A of the Code for calendar year 2005. There will be no assertion of penalties against service providers in certain circumstances.

This notice provides tables that show the amount of an individual’s salary, wages, or other income that is exempt from a notice of levy used to collect delinquent tax in 2006.

ADMINISTRATIVE

Final regulations under section 6043 of the Code require information reporting by a corporation if control of the corporation is acquired or the corporation has a substantial change in capital structure, and the corporation or any shareholder is required to recognize gain (if any) under section 367(a) and the regulations. The regulations also pertain to information reporting requirements for brokers with respect to transactions described in section 6043(c).

This notice contains a proposed revenue procedure that would provide guidance to tax return preparers regarding the format and content of consents to use and consents to disclose tax return information under proposed section 301.7216-3 of the regulations, which was filed with the Federal Register contemporaneously with the public release of this notice on December 7, 2005. The proposed revenue procedure would also provide specific requirements for electronic signatures when a taxpayer executes an electronic consent to the use or disclosure of the taxpayer’s tax return information.



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