Proposed regulations under section 446 of the Code provide that, subject to certain exceptions (including the full margin exception), a notional principal contract with a nonperiodic payment must be treated as two separate transactions consisting of one or more loans and an on-market, level payment swap. The proposed regulations also provide an exception under section 956 of the Code from the definition of United States property for certain obligations of United States persons arising from upfront payments made with respect to notional principal contracts that qualify for the full margin exception under section 446. These regulations also withdraw the notice of proposed rulemaking (REG–107548–11; RIN 1545–BK10) published in the Federal Register on May 11, 2012 (77 FR 27669).

This document contains proposed regulations that provide guidance regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code. Specifically, the proposed regulations will modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

This document contains proposed regulations under section 7704(d)(1)(E) of the Internal Revenue Code relating to qualifying income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or natural resources. The proposed regulations affect publicly traded partnerships and their partners.

This ruling holds that the transaction described is properly treated for federal income tax purposes as a transfer of stock in an exchange governed by § 351 of the Internal Revenue Code (Code) followed by reorganizations under § 368(a)(1)(D) of the Code. Rev. Rul. 78–130, 1978–1 C.B. 114 is revoked.

This ruling holds that the transaction described is properly treated for federal income tax purposes as two transfers of stock in exchanges governed by § 351 of the Internal Revenue Code (Code) followed by a reorganization under § 368(a)(1)(D) of the Code.

The revenue ruling holds that the cost of unrecoverable precious metals used in various manufacturing processes are depreciable under §§ 167 and 168 of the Internal Revenue Code. The costs of any recoverable precious metals are not depreciable.

Final, temporary and proposed regulations under section 446 of the Code provide that, subject to certain exceptions (including the full margin exception), a notional principal contract with a nonperiodic payment must be treated as two separate transactions consisting of one or more loans and an on-market, level payment swap. These regulations also provide an exception under section 956 of the Code from the definition of United States property for certain obligations of United States persons arising from upfront payments made with respect to notional principal contracts that qualify for the full margin exception under section 446.

This document contains proposed regulations that provide guidance regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code. Specifically, the proposed regulations will modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

This document contains proposed regulations that provide guidance regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code. Specifically, the proposed regulations will modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

This document contains proposed regulations that provide guidance regarding the application of the modified carryover basis rules of section 1022 of the Internal Revenue Code. Specifically, the proposed regulations will modify provisions of the Treasury Regulations involving basis rules by including a reference to section 1022 where appropriate. The regulations will affect property transferred from certain decedents who died in 2010. The regulations reflect changes to the law made by the Economic Growth and Tax Relief Reconciliation Act of 2001 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

This Notice updates the list of designated private delivery service (“designated PDSs”) set forth in Notice 2004–83, 2004–2 C.B. 1030, for purposes of the timely mailing treated as timely filing/paying rule of section 7502 of the Internal Revenue Code, providing rules for determining the postmark date for these services, and provides a new address for submitting documents to the Internal Revenue Service (“IRS”) with respect to an application for designation as a designated PDS.