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This notice addresses the U.S. tax imposed on substitute dividend payments received by foreign taxpayers that lend U.S. dividend paying securities in securities lending transactions. The notice announces the upcoming withdrawal of Notice 97-66, outlines a proposed regulatory framework to address potential over-withholding that may occur as a result of the HIRE Act, and provides transaction relief with respect to substitute dividend payments made between the effective date of the HIRE Act and the issuance of regulations. Notice 97-66 modified.
Final regulations under section 401(a)(35) of the Code relate to diversification requirements for certain defined contribution plans holding publicly traded employer securities. The regulations will affect administrators of, employers maintaining, participants in, and beneficiaries of defined contribution plans that are invested in employer securities. The regulations apply for plan years beginning on or after January 1, 2011.
This notice solicits comments regarding the application of certain requirements imposed by new section 501(r), added to the Code by section 9007(a) of the Patient Protection and Affordable Care Act (Affordable Care Act). Comments should be submitted by July 22, 2010.
Qualified mortgage bonds; mortgage credit certificates; national median gross income. Guidance is provided concerning the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit certificates in determining the housing cost/income ratio described in section 143(f) of the Code. Rev. Proc. 2009-27 obsoleted in part.
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