Final regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax and make conforming amendments under sections 6111 and 6112. The regulations provide guidance under section 6112 regarding the length of time a material advisor has to prepare the list that must be maintained after the list maintenance requirement first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements.

Final regulations under section 108 of the Code provide guidance in determining the discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership’s indebtedness, provide that section 721 generally applies to a contribution of a partnership’s indebtedness by a creditor to the partnership in exchange for an interest in the partnership, and provide guidance for how a partnership’s discharge of indebtedness income is allowed as a minimum gain chargeback under section 704.

Temporary regulations under section 358 of the Code clarify that, in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction, the ability to designate the share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the issuing corporation.

Temporary regulations under section 358 of the Code clarify that, in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction, the ability to designate the share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the issuing corporation.

This announcement informs bankruptcy trustees (or debtors-in-possession) of a change of address for the Centralized Insolvency Operation that should be used for the submission of requests for tax refunds under section 505(a) of the Bankruptcy Code or requests for prompt determinations of any unpaid tax liability of the estate incurred during the bankruptcy case under section 505(b) of the Bankruptcy Code. Rev. Procs. 2010-27 and 2006-24 modified.

This announcement describes a correction to final and temporary regulations (T.D. 9554, 2011-50 I.R.B. 843) extending the exceptions from taxes under the Federal Insurance Contributions Act (“FICA”) and the Federal Unemployment Tax Act (“FUTA”) under sections 3121(b)(3) (concerning individuals who work for certain family members), 3127 (concerning members of religious faiths), and 3306(c)(5) (concerning persons employed by children and spouses and children under 21 employed by their parents) of the Code to entities that are disregarded as separate from their owners for Federal tax purposes. The temporary regulations also clarify the existing rule that the owners of disregarded entities, except for qualified subchapter S subsidiaries, are responsible for backup withholding and related information reporting requirements under section 3406.

This announcement describes rules that the Treasury Department and the IRS are considering proposing relating to the determination of whether a plan is a governmental plan within the meaning of section 414(d) of the Code and contains an appendix that includes a draft notice of proposed rulemaking on which Treasury Department and IRS invite comments.

This announcement describes rules that the Treasury Department and the IRS are considering proposing relating to the determination of whether a plan of an Indian tribal government is a governmental plan within the meaning of section 414(d) of the Code and contains an appendix that includes a draft notice of proposed rulemaking on which Treasury Department and IRS invite comments.

Final regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax and make conforming amendments under sections 6111 and 6112. The regulations provide guidance under section 6112 regarding the length of time a material advisor has to prepare the list that must be maintained after the list maintenance requirement first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements.

Proposed regulations will amend regulations section 20.2032-1 to provide guidance that clarifies for the executor of an estate that elects to use the alternate valuation method under section 2032 of the Code what constitutes a distribution, sale, exchange, or other disposition and what post-death occurrences the executor may consider when valuing property includible in the gross estate on the alternate valuation date. A public hearing is scheduled for March 9, 2012.

This announcement informs bankruptcy trustees (or debtors-in-possession) of a change of address for the Centralized Insolvency Operation that should be used for the submission of requests for tax refunds under section 505(a) of the Bankruptcy Code or requests for prompt determinations of any unpaid tax liability of the estate incurred during the bankruptcy case under section 505(b) of the Bankruptcy Code. Rev. Procs. 2010-27 and 2006-24 modified.

This announcement informs bankruptcy trustees (or debtors-in-possession) of a change of address for the Centralized Insolvency Operation that should be used for the submission of requests for tax refunds under section 505(a) of the Bankruptcy Code or requests for prompt determinations of any unpaid tax liability of the estate incurred during the bankruptcy case under section 505(b) of the Bankruptcy Code. Rev. Procs. 2010-27 and 2006-24 modified.

Final regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax and make conforming amendments under sections 6111 and 6112. The regulations provide guidance under section 6112 regarding the length of time a material advisor has to prepare the list that must be maintained after the list maintenance requirement first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements.

This announcement informs bankruptcy trustees (or debtors-in-possession) of a change of address for the Centralized Insolvency Operation that should be used for the submission of requests for tax refunds under section 505(a) of the Bankruptcy Code or requests for prompt determinations of any unpaid tax liability of the estate incurred during the bankruptcy case under section 505(b) of the Bankruptcy Code. Rev. Procs. 2010-27 and 2006-24 modified.