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IRB 2011-48

Table of Contents
(Dated November 28, 2011)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2011-48. 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

Geographical areas included in North American area. This ruling contains an updated list of all geographical areas included in the North American area for purposes of section 274 of the Code. Rev. Rul. 2007-28 superseded.

Section 1274A - inflation adjusted numbers for 2012. This ruling provides the dollar amounts, increased by the 2012 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2010-30 supplemented and superseded.

Proposed regulations under section 892 of the Code relate to the taxation of certain investment income earned by foreign governments in the United States.

Proposed regulations under section 964 of the Code clarify and add examples illustrating the application of final regulations relating to the procedures for U.S. shareholders of foreign corporations to make tax accounting elections on behalf of the foreign corporations for purposes of computing the foreign corporation’s earnings and profits for U.S. tax purposes. The regulations also update the rules relating to required book-to-tax adjustments in respect of depreciation and amortization and contain a rule related to mandated changes in methods of accounting in connection with an audit or audits of a foreign corporation’s controlling domestic shareholders.

This announcement notifies taxpayers that the Service has withdrawn Weld Rite, Inc.’s right to certify its hydronic outdoor wood-burning furnaces. Therefore, this announcement also notifies taxpayers that they may no longer rely on Weld Rite, Inc.’s certification statement to claim a section 25C credit for the furnaces.

This document contains a withdrawal of proposed regulations (REG-158677-05, 2007-1 C.B. 975) clarifying that if a bank is an S corporation within the meaning of section 1361(a)(1) of the Code, its status as an S corporation does not affect the applicability of the special rules for banks under the Internal Revenue Code.

EMPLOYEE PLANS

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in November 2011; the 24-month average segment rates; the funding transitional segment rates applicable for November 2011; and the minimum present value transitional rates for October 2011. In addition, the Service requests comments on whether these monthly interest rate notices should continue to provide the Composite Corporate Bond Rate and the Corporate Bond Weighted Average in 2012.

EMPLOYMENT TAX

Final regulations under section 7701 of the Code clarify that a single-owner eligible entity that is generally disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for those excise tax purposes. The regulations also make conforming changes to the tax liability rule for disregarded entities and the treatment of entity rule for disregarded entities with respect to employment taxes. The regulations affect disregarded entities in general and, in particular, disregarded entities that pay or pay over certain federal excise taxes or that are required to be registered by the IRS.

EXCISE TAX

Final regulations under section 7701 of the Code clarify that a single-owner eligible entity that is generally disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for those excise tax purposes. The regulations also make conforming changes to the tax liability rule for disregarded entities and the treatment of entity rule for disregarded entities with respect to employment taxes. The regulations affect disregarded entities in general and, in particular, disregarded entities that pay or pay over certain federal excise taxes or that are required to be registered by the IRS.

This notice provides guidance on the branded prescription drug fee for the 2012 fee year related to (1) the submission of Form 8947, “Report of Branded Prescription Drug Information”, (2) the time and manner for notifying covered entities of the preliminary fee calculation, (3) the time and manner for submitting error reports for the dispute resolution process, and (4) the time for notifying covered entities of their final fee calculation. Rev. Proc. 2011-24 obsoleted.

TAX CONVENTIONS

Geographical areas included in North American area. This ruling contains an updated list of all geographical areas included in the North American area for purposes of section 274 of the Code. Rev. Rul. 2007-28 superseded.

ADMINISTRATIVE

Final regulations under section 7701 of the Code clarify that a single-owner eligible entity that is generally disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for those excise tax purposes. The regulations also make conforming changes to the tax liability rule for disregarded entities and the treatment of entity rule for disregarded entities with respect to employment taxes. The regulations affect disregarded entities in general and, in particular, disregarded entities that pay or pay over certain federal excise taxes or that are required to be registered by the IRS.

This document contains a withdrawal of proposed regulations (REG-158677-05, 2007-1 C.B. 975) clarifying that if a bank is an S corporation within the meaning of section 1361(a)(1) of the Code, its status as an S corporation does not affect the applicability of the special rules for banks under the Internal Revenue Code.



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