This is the table of contents of Internal Revenue Bulletin IRB 2012-29. 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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Final regulations under section 1502 of the Code provide for an election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. Pursuant to the election, the liquidation, followed by a recontribution of assets, will be recharacterized as a cross-chain reorganization, rather than a liquidation or an upstream reorganization followed by a drop of assets.
Proposed regulations under section 904(f)(3) of the Code provide proposed rules regarding the recapture of overall foreign losses on certain dispositions of property, as well as the coordination of the rules for determining high-taxed income under section 904(d) with section 904(b), (f) and (g).
This notice provides guidance under section 1297 of the Code regarding the treatment of income from certain government bonds held by certain active banks for purposes of determining whether a foreign corporation is a passive foreign investment company (PFIC).
Proposed regulations under section 411(d)(6) of the Code provide guidance under the anti-cutback rules which generally prohibit plan amendments eliminating or reducing accrued benefits, early retirement benefits, retirement-type subsidies, and optional forms of benefit under qualified retirement plans. These proposed regulations would provide an additional limited exception to the anti-cutback rules to permit a plan sponsor that is a debtor in a bankruptcy proceeding to amend its single-employer defined benefit plan to eliminate a single-sum distribution option (or other optional form of benefit providing for accelerated payments) under the plan if certain specified conditions are satisfied. A public hearing is scheduled for August 24, 2012.
Proposed regulations under sections 6057 and 6081 of the Code relate to the reporting and notice requirements for deferred vested benefits. These proposed regulations would affect administrators of, employers maintaining, participants in, and beneficiaries of, plans that are subject to the reporting and participant notice requirements.
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