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IRB 2010-06

Table of Contents
(Dated February 8, 2010)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2010-06. 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

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2010.

Final, temporary, and proposed regulations under section 304 of the Code address the tax treatment of certain shareholders who transfer stock or securities to related corporations. When shareholders control two corporations and sell the stock or securities of one controlled corporation to the other, section 304 governs the tax treatment of the shareholders on the amounts received for the transferred stock or securities. The regulations provide that shareholders will not avoid the application of section 304 by causing controlled corporations to form or avail themselves of related corporations to execute the transaction.

Final, temporary, and proposed regulations under section 304 of the Code address the tax treatment of certain shareholders who transfer stock or securities to related corporations. When shareholders control two corporations and sell the stock or securities of one controlled corporation to the other, section 304 governs the tax treatment of the shareholders on the amounts received for the transferred stock or securities. The regulations provide that shareholders will not avoid the application of section 304 by causing controlled corporations to form or avail themselves of related corporations to execute the transaction.

Haiti earthquake in 2010. This notice designates the Haiti earthquake occurring in January 2010 as a qualified disaster for purposes of section 139 of the Code.

EMPLOYEE PLANS

Miscellaneous HEART Act changes. This notice provides guidance in the form of questions and answers with respect to certain provisions of the Heroes Earnings Assistance and Relief Act of 2008 (“HEART Act”). The notice also requests comments regarding any additional issues relating to sections of the HEART Act that are addressed in the notice.

EMPLOYMENT TAX

Proposed regulations under section 3504 of the Code relate to employment tax liability of agents authorized by the Secretary to perform acts required of employers with respect to Federal Unemployment Tax Act (FUTA) taxes on wages paid for home care services, as defined in these regulations. The regulations would allow an enrolled participant in a home care services program to designate an agent to report, file, and pay all employment taxes, including federal unemployment taxes. The change will allow an agent to file a single federal unemployment tax return for multiple home care service recipients.

ADMINISTRATIVE

This document contains a correction to Revenue Procedure 2010-1, 2010-1 I.R.B. 1, which contained an incorrect internal cross-reference.

This announcement provides notice of a public hearing on proposed regulations (REG-127270-06, 2009-42 I.R.B. 534) relating to the exclusion from gross income for amounts received on account of personal physical injuries or physical sickness. A public hearing is scheduled for February 23, 2010.

This document contains a correction to temporary regulations (T.D. 9458, 2009-43 I.R.B. 547) relating to modification to consolidated return regulation permitting an election to treat a liquidation of a target, followed by a recontribution to a new target, as a crosschain reorganization.



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