Final, temporary, and proposed regulations under section 367 of the Code provide rules for the treatment of certain shareholders who transfer stock or securities of controlled corporations to foreign corporations. The regulations also address certain distributions shareholders receive with respect to the stock of controlled foreign corporations.

Final, temporary, and proposed regulations under section 367 of the Code provide rules for the treatment of certain shareholders who transfer stock or securities of controlled corporations to foreign corporations. The regulations also address certain distributions shareholders receive with respect to the stock of controlled foreign corporations.

Final regulations under section 6103 of the Code relate to administrative review procedures for certain government agencies and other authorized recipients of returns or return information whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards.

Final regulations under section 367 of the Code provide rules for entering into gain recognition agreements under section 367(a). The regulations clarify the effect that various transactions have on existing gain recognition agreements. Notice 2005-74 obsoleted.

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

The IRS has revoked its determination that Leszinski Family Support Organization of Atlanta, GA; Kuumba Trust of Pittsburgh, PA; Consumer Debt Management Services of Deerfield Beach, FL; RealtyAmerica.Org, Inc., of Indian Harbour Beach, FL; Consumer Budget Counseling, Inc., of Port Charlotte, FL; Innovative Womens Network, Inc., of Houston, TX; Ellen Stephen Hospice & Home Care of Kyle, SD; Starfish Foundation, Inc., of Richardson, TX; Ronsard Foundation of Statesville, NC; Alternative Care, Inc., of Gainesville, FL; Credit Counseling, Inc., of Sunrise, FL; A New Goal Credit Counseling Agency of San Francisco, CA; Trans-Atlantic Health Organization, Inc., of Gaithersburg, MD; and Ammend Credit Counseling and Debt Consolidation of Cincinnati, OH, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

Final regulations under section 6103 of the Code relate to administrative review procedures for certain government agencies and other authorized recipients of returns or return information whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards.

Proposed regulations under section 6231 of the Code allow the IRS to convert partnership items to nonpartnership items when the application of the unified partnership audit and litigation procedures of sections 6221 through 6234 with respect to certain tax avoidance transactions interferes with the effective and efficient enforcement of the Internal Revenue laws. A public hearing is scheduled for June 4, 2009.

New section 6050W of the Code requires information reporting for payment card and third party payment network transactions, effective for returns for calendar years beginning after December 31, 2010. Entities required to report must perform backup withholding if the payee fails to furnish a correct Taxpayer Identification Number (“TIN”). This announcement will alert 6050W filers that they may now participate in the TIN matching program.