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IRB 2010-36

Table of Contents
(Dated September 7, 2010)
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This is the table of contents of Internal Revenue Bulletin IRB 2010-36. 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 September 2010.

This procedure describes the conditions under which the Service will not challenge a mortgage loan held by a REMIC as other than a ”qualified mortgage” on the grounds that the mortgage loan fails to be principally secured by an interest in real property following the release of a lien on an interest in real property that secures the mortgage loan.

TAX CONVENTIONS

This is a Competent Authority Agreement entered into on July 14, 2010, by the competent authorities of the United States of America and Belgium with respect to the taxation of fellowship payments made to certain researchers under the U.S.-Belgium income tax treaty and protocol.

ADMINISTRATIVE

This procedure provides that if a foreign entity makes a check the box election to be a partnership (under the reasonable assumption that it has more than one owner) but then determines it only had one owner, the original check the box election will be treated as an election to be a disregarded entity provided the requirements in the revenue procedure are satisfied. Similarly, it also provides that if a foreign entity makes a check the box election to be disregarded entity (under the reasonable assumption that it has only one owner) but then determines it only had more than one owner, the original check the box election will be treated as an election to be a partnership provided the requirements in the revenue procedure are satisfied.



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