This is the table of contents of Internal Revenue Bulletin IRB 2009-21. 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.
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.
The Department of Treasury and the Service invite public comments on recommendations for items that should be included on the 2009-2010 Guidance Priority List. Taxpayers may submit recommendations for guidance at any time during the year. Recommendations submitted by May 31, 2009, will be reviewed for possible inclusion on the original 2009-2010 Guidance Priority List. Recommendations received after May 31, 2009, will be reviewed for inclusion in the next periodic update.
Primary sale of life insurance contract; tax treatment of a sale or surrender. This ruling provides guidance to policyholders who surrender or sell their life insurance contracts.
Secondary sale of life insurance contract by investors. This ruling provides guidance to investors who purchase life insurance contracts.
Formless conversion of partnership to S corporation. This ruling explains that a partnership that converts to a corporation under either regulations section 301.7701-3(c)(1)(i) or under a state law formless conversion statute is allowed to make an S election effective for the corporation’s first taxable year.
This notice clarifies that, under regulations section 1.42-10 (the utility allowance regulations), utility costs paid by a tenant based on actual consumption in a sub-metered rent-restricted unit are treated as paid directly by the tenant for purposes of section 42(g)(2)(B)(ii) of the Code.
This document contains corrections to final regulations (T.D. 9446, 2009-9 I.R.B. 607) concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations.
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