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IRB 2009-20

Table of Contents
(Dated May 18, 2009)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2009-20. 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

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

Self-determination of deficiency dividend under section 860(e)(4). This document provides procedures for regulated investment company (RIC) and real estate investment trust (REIT) self-determinations under section 860(e)(4) of the Code for purposes of the deficiency dividends procedures of section 860.

EMPLOYEE PLANS

Extension of date for multiemployer plans to elect relief under sections 204 and 205 of WRERA. This notice provides guidance to multiemployer plans making elections described in sections 204 and 205 of the Worker, Retiree, and Employer Recovery Act of 2008, P.L. 110-458 (WRERA). This notice also extends the time period for making elections described in section 204. This notice hereby substitutes “June 30, 2009,” for “April 30, 2009” in the paragraph above and wherever else it appears in Notice 2009-31. Notice 2009-31 modified.

EXEMPT ORGANIZATIONS

The IRS has revoked its determination that the Michael and Laura Gallop Family Foundation of Agoura Hills, CA; Physician Directed Care of Southfield, MI; Winston County Community Development Corporation of Louisville, MS; EMF Debt Management, Inc., of Pittsburgh, PA; Lil Pals & Gals Daycare Center Association of Tulsa, OK; Heartland Women’s Foundation, Inc., of Tribune, KS; CF Moore Charitable Foundation of Chicago, IL; Waimano Auxiliary, a/k/a Kokua Mau Work Center, of Ewa Beach, HI; The American Dream of West Jordan, UT; Henry Jacobson Family Foundation of Ross, CA; Dreamkeepers of America, Inc., of Memphis, TN; Community Workshop on Economic Development of Pueblo, CO; Hope Alive, Inc., of Pueblo, CO; Building Successful Lifestyles, Inc., of Topeka, KS; Hummingbird Tribal Foundation of Woodside, CA; Diamond-A-CAT-A-ME, Inc., of Houston, TX; Constitutional Educational Research Foundation of Rancho Cordova, CA; and Family Home Providers, Inc., of Cumming, GA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

ESTATE TAX

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

Proposed regulations under section 2036 of the Code provide guidance on the portion of trust property includible in the grantor’s gross estate if the grantor has retained the use of the property, the right to an annuity, unitrust, graduated retained interest, or other payment from such property for life, for any period not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death.

GIFT TAX

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.

ADMINISTRATIVE

This document contains corrections to final and temporary regulations (T.D. 9441, 2009-7 I.R.B. 460) providing further guidance and clarification regarding methods under section 482 of the Code to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations.

This document contain corrections to proposed regulations (REG-143686-07, 2009-8 I.R.B. 579) providing guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies, as well as guidance regarding the determination of gain and the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions.

This document contains corrections to final regulations (T.D. 9394, 2008-21 I.R.B. 988) regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership’s obligation to pay withholding tax under section 1446 on effectively connected taxable income allocable under section 704 to such partner.



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