Issue

Date

Subject

2005-343

December 30, 2005

• Final Regulations on Designated Roth Contributions to Cash or Deferred Arrangements Under Section 401(k)

2005-342

December 30, 2005

• Temporary, Proposed Regulations for Filing Employment Tax Returns, Include Changes to Deposit Rules

2005-341

December 29, 2005

• Section 7874 Anti-Inversion Temporary and Proposed Regulations

2005-340

December 29, 2005

• Simplified Safe Harbor Method for Pre-2006 Roth IRA Conversions Relating to Determining Fair Market Value of Annuity Contract

2005-339

December 29, 2005

• Information Reporting and Other Guidance for Distributions Relating to Securities Issued by Foreign Corporations

2005-338

December 29, 2005

• IRS Interim Guidance on Application of Section 409A to Outstanding Stock Rights

2005-337

December 22, 2005

• Pennsylvania: Change in Administrative Policy Concerning Resettlement Requests by Taxpayers May Require Immediate Action

2005-336

December 22, 2005

• Legislative Update: Congress to Adjourn for the Year Without Final Passage of Expiring Tax Provisions, Pension Reform; President Bush Signs Hurricane Tax Relief Bill That Includes Technical Corrections

2005-335

December 21, 2005

• Rev. Proc 2006-12 Provides Procedures for Changes in Method of Accounting Under the INDOPCO Regulations

2005-334

December 21, 2005

• Rev. Proc 2006-11 Provides Procedures for Changes in Method of Accounting to Comply with Section 263

2005-333

December 20, 2005

• IRS Will Not Recognize Certain Claimed Deductions Relating to Donated Vehicles Sold at Auction

2005-332

December 20, 2005

• Proposed Regulations on Normalization Requirements for Public Utilities Benefiting from Accelerated Depreciation or Investment Tax Credit

2005-331

December 20, 2005

• IRS Releases Schedule M-3 for Partnerships

2005-330

December 20, 2005

• Massachusetts: Tax Legislation Enacted

2005-329

December 20, 2005

• IRS Revokes Section 351 Zero-Basis Revenue Ruling

2005-328

December 20, 2005

• Final Regulations on Applicability of Section 1374 to S Corporations Acquiring Assets in Carryover Basis Transactions from C Corporations

2005-327

December 19, 2005

• IRS to Increase Some User Fees in February 2006

2005-326

December 19, 2005

• Successor Entity To Japanese Yugen Kaisha (YK) Is Eligible Entity Under Check-the-Box Regulations—IRS Revenue Ruling

2005-325

December 19, 2005

• IRS Guidance on Investments by Mutual Funds in Commodity-Index Contracts

2005-324

December 19, 2005

• IRS Extends Code Section 470 Transition Relief to Partnerships and Pass-Thru Entities to Tax Years Beginning Before January 1, 2006

2005-323

December 16, 2005

• Final Regulations on Private Activity Bonds

2005-322

December 16, 2005

• IRS Guidance for Qualifying as Acceptance Agent, and Agreements Relating to the Issuance of Certain Taxpayer Identifying Numbers

2005-321

December 16, 2005

• Legislative Update: Description of Provisions in Hurricane Tax Relief Bill Passed Today by the Senate and House

2005-320

December 16, 2005

• Legislative Update: Senate Passes Hurricane Tax Relief Bill

2005-319

December 16, 2005

• Texas: Taxpayers Only Have 30 Days in Which to Appeal Denial of Franchise Tax Refund Claims

2005-318

December 15, 2005

• Legislative Update: Text and Description of Senate Amendment to Gulf Opportunity Zone Act

2005-317

December 15, 2005

• Legislative Update: House Votes to Approve Pension Legislation

2005-316

December 15, 2005

• Final Regulations Treat Societas Europaea and Certain Other Foreign Entities as “Per Se” Corporations

2005-315

December 14, 2005

• Final Regulations on FICA Treatment of Workers’ Compensation Payments

2005-314

December 13, 2005

• IRS Issues Schedules M-3 for Insurance and S Corporations

2005-313

December 12, 2005

• Legislative Update: Joint Committee Releases Revenue Estimates of Bills Passed by the House

2005-312

December 12, 2005

• Court of Federal Claims Finds Statute of Limitations Was Closed for Global Interest Netting Purposes

2005-311

December 12, 2005

• 2005 Cumulative List of Changes in Plan Qualification Requirements

2005-310

December 12, 2005

• Reminder: Year-End Actions for Certain Deferred Compensation Arrangements

2005-309

December 9, 2005

• Legislative Update: Side-by-Side Comparison of Measures to Extend Expiring Provisions in House, Senate Tax Reconciliation Bills

2005-308

December 9, 2005

• Legislative Update: Side-by-Side Comparison of Hurricane Tax Relief Provisions in Senate, House Bills

2005-307

December 9, 2005

• D.C. Circuit Joins Sixth, Eleventh Circuits in Holding Long-Distance Telephone Service Not Subject to Federal Communications Excise Tax

2005-306

December 8, 2005

• IRS Suspends Reporting and Wage Withholding Requirements for Deferrals Under Section 409A for 2005

2005-305

December 8, 2005

• Legislative Update: House Passes Tax Reconciliation

2005-304

December 7, 2005

• Legislative Update: House to Consider Katrina Tax Relief Bill Today

2005-303

December 7, 2005

• Proposed Regulations, Proposed Revenue Procedure on Disclosure or Use of Tax Return Information by Return Preparers

2005-302

December 7, 2005

• Guidance on Passive Foreign Investment Company (PFIC) Purging Elections

2005-301

December 7, 2005

• Proposed Regulations Provide Updated Guidance Relating to Corporate Estimated Taxes

2005-300

December 6, 2005

• IRS Requests Comments on Procedures for Automatic Changes in Method of Accounting Contained in Rev. Proc. 2002-9

2005-299

December 6, 2005

• U.S. Supreme Court Upholds State Fuel Tax Imposed on Off-Reservation Fuel Transactions Between Non-Indians

2005-298

December 6, 2005

• Legislative Update: Text of Tax Relief Act of 2005, as Passed by the Senate

2005-297

December 5, 2005

• Third Circuit Reverses Tax Court in Case Concerning the Valuation of Cancelled Insurance Contracts

2005-296

December 5, 2005

• Legislative Update: Additional Provisions in the Senate’s Tax Relief Bill Include Proposals to Modify Application of FIRPTA to Distributions From RICs

2005-295

December 5, 2005

• Legislative Update: Proposed Changes to Rules for Distributions of Controlled Corporations in the Senate’s Tax Bill

2005-294

December 2, 2005

• IRS Announces Standard Mileage Allowance of 44.5 Cents Per Mile for 2006

2005-293

December 2, 2005

• IRS Provides Transitional Relief for Certain Plan Amendment Deadlines

2005-292

December 2, 2005

• Final Regulations Concerning Information Reporting Relating to Corporate Inversions

Issue

Date

Subject

2005-291

November 30, 2005

• IRS’s Revenue Ruling on Tax Treatment of Sales of Employee Homes Using Relocation Service Programs

2005-290

November 30, 2005

• IRS Provides an Exception to the Application of Section 901(l) for Foreign Withholding Taxes Imposed on Royalty Payments in a Back-to-Back Computer Program Licensing Arrangement

2005-289

November 30, 2005

• Additional IRS Guidance Clarifies How Hurricane Katrina Victims May Access Their Retirement Savings

2005-288

November 29, 2005

• IRS Releases Guidance on Withholding on Payments to Partnerships, Trusts and Estates

2005-287

November 23, 2005

• IRS Extends the Date for Qualified Retirement Plans to Satisfy Operational Compliance Pursuant to Rev. Proc. 2005-23

2005-286

November 23, 2005

• Legislative Update: Certain Revenue Raisers Included in the Senate Bill

2005-285

November 23, 2005

• Legislative Update: Charitable Giving Incentive and Charitable Organization Reform Provisions in the Senate Bill

2005-284

November 23, 2005

• Legislative Update: Provisions in the Senate Bill Concerning Oil and Gas Companies, Including Revaluation of LIFO Inventories of Large Integrated Oil Companies

2005-283

November 22, 2005

• Legislative Update: Tax Benefits in the Senate Bill for Areas Affected by Hurricanes

2005-282

November 22, 2005

• Legislative Update: Practice and Procedure Changes in Tax Reconciliation Bill Approved by the Senate, Including Codification of the Economic Substance Doctrine

2005-281

November 22, 2005

• Family Members Making an Election to Be Treated as a Single S Corporation Shareholder May Rely on IRS Notice Until Future Guidance Is Issued

2005-280

November 22, 2005

• IRS Notice Provides Guidance on FSA Grace Period and HSA Eligibility

2005-279

November 22, 2005

• IRS Guidance for REITs Owning Lodging Facilities Used to Provide Temporary Housing to Hurricane Victims

2005-278

November 21, 2005

• Tax Court: Prior Approval Purchase Contracts Were “Put” Options, and Taxpayer Properly Reported Nonrefundable Portion of Commitment Fees as Option Premiums

2005-277

November 21, 2005

• Legislative Update: Proposed Changes to Tax Rules on Expatriation of Individuals Approved by the Senate

2005-276

November 21, 2005

• Legislative Update: Proposed Changes to Tax Treatment of Inversion Transactions Approved by the Senate

2005-275

November 21, 2005

• Legislative Update: Extension and Modification of Expiring Provisions Approved by the Senate

2005-274

November 21, 2005

• Legislative Update: JCT Estimate of Expiring Provisions in House Ways and Means Proposal

2005-273

November 18, 2005

• Legislative Update: Senate Passes Tax Reconciliation Bill, with Amendments

2005-272

November 17, 2005

• Tax Court: Value of IRAs Included in Gross Estate Is Not Reduced by Anticipated Income Tax Liability

2005-271

November 17, 2005

• Proposed Regulations Concerning Determination of Partners’ Distributive Share Under Section 704(b)

2005-270

November 17, 2005

• Legislative Update: Senate Passes Pension Reform Bill

2005-269

November 16, 2005

• Legislative Update: House Ways and Means Approves Tax Reconciliation; Senate Finance Committee Statutory Language Now Available

2005-268

November 16, 2005

• IRS Releases 2006 Inflation Adjustments for Loans to Qualifying Continuing Care Facilities, and for Debt Instruments Given in Sale or Exchange of Non-Publicly Traded Property

2005-267

November 15, 2005

• Legislative Update: Finance Committee Approves Revised Chairman’s Mark for Tax Reconciliation; Ways and Means to Consider Revised Chairman’s Mark This Evening

2005-266

November 15, 2005

• IRS Reminds Partnerships and S Corporations Whose Fiscal Years End After August 27, 2005, of Katrina-Related Benefits for Charitable Contributions

2005-265

November 11, 2005

• Legislative Update: Ways and Means to Consider Tax Reconciliation

2005-264

November 10, 2005

• IRS Issues Waiver Guidance for Corporations Unable to Comply with Electronic Return Filing Requirements; KPMG’s Audio Webcast, November 18th, to Address Electronic Filing Issues

2005-263

November 10, 2005

• Legislative Update: Finance Committee Postpones Tax Bill Markup; Ways and Means Approves Pension Reform Bill

2005-262

November 8, 2005

• Legislative Update: Finance Committee to Consider $69 Billion Tax Cut

2005-261

November 7, 2005

• IRS Adds Model Year 2006 Ford and Mercury Hybrid Vehicles to List of Vehicles Eligible for Clean-Burning Fuel Deduction

2005-260

November 7, 2005

• Deadlines for IRS Actions Concerning Taxpayers Affected by Hurricanes Katrina and Rita Are Extended to February 28, 2006

2005-259

November 4, 2005

• Regulations Are Intended to Simplify the Rules for Obtaining Automatic Six-Month Extensions of Time to File Returns

2005-258

November 3, 2005

• IRS Extends Section 1441 Voluntary Compliance Initiative for Use by Withholding Agents to March 31, 2006

2005-257

November 3, 2005

• Proposed Regulations on Domestic Production Activities Deduction Under Section 199 Are Released for Publication in the Federal Register

2005-256

November 2, 2005

• Sixth Circuit: Long-Distance Telephone Service Not Subject to Federal Communications Excise Tax

2005-255

November 1, 2005

• Legislative Update: Tax Reform Panel Releases Proposal

Issue

Date

Subject

2005-254

October 31, 2005

• Notices on Nonresident Wage Withholding, Filing Requirements

2005-253

October 31, 2005

• HSA and MSA Cost-of-Living Adjustments for 2006

2005-252

October 28, 2005

• IRS Releases Inflation Adjustments for 2006

2005-251

October 28, 2005

• Legislative Update: House Leader Proposes Katrina Tax Bill

2005-250

October 28, 2005

• Additional Relief for Certain Employee Benefit Plans Because of Hurricane Katrina

2005-249

October 27, 2005

• IRS Offers Abusive-Transaction Settlement Initiative

2005-248

October 27, 2005

• Legislative Update: Leaders Weigh Options for Tax Cuts

2005-247

October 25, 2005

• South Asia Earthquake Is Designated “Qualified Disaster” for Purposes of Providing Tax-Free Assistance to Victims

2005-246

October 21, 2005

• Court of Federal Claims Grants Summary Judgment for Government in Deficiency Interest Case

2005-245

October 21, 2005

• IRS Provides Guidance on Certain Fuel-Related Excise Tax Provisions Recently Added to the Code

2005-244

October 20, 2005

• IRS Will Continue to Require Collection and Payment of Federal Communications Excise Tax on Certain Long-Distance Telephone Services, Despite Court Losses

2005-243

October 20, 2005

• Proposed Regulations on Domestic Production Activities Deduction Under Section 199

2005-242

October 17, 2005

• Regulations Propose to Treat Disregarded Entities as Separate Entities for Employment, Excise Tax Purposes

2005-241

October 14, 2005

• IRS Announces 2006 Pension Plan Limitations

2005-240

October 13, 2005

• California: Internal Revenue Code Conformity Legislation Is Enacted

2005-239

October 12, 2005

• Tax Court Finds Prohibited Ex Parte Communication Between IRS Appeals and IRS Collection

2005-238

October 10, 2005

• Reminder: New Requirements for Certain Large Corporations to File Their Income Tax Returns Electronically

2005-237

October 6, 2005

• Clarification: Taxpayers in Only Certain Texas Counties, Affected by Hurricane Rita, Qualify for Automatic Tax Relief

2005-236

October 3, 2005

• Protocol to United States-Sweden Income Tax Treaty Is Signed: New Zero Rate on Dividends, Revised Limitation on Benefits Article, and Fiscally Transparent Entity Rules Similar to 2001 United States-United Kingdom Income Tax Treaty

Issue

Date

Subject

2005-235

September 30, 2005

• WTO Releases Report on Tax Treatment of FSC/ETI Regime After the American Jobs Creation Act of 2004

2005-234

September 30, 2005

• Analysis of Third Notice Issued by Treasury, IRS on Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004

2005-233

September 29, 2005

• Proposed Regulations on Deferred Compensation Under Section 409A

2005-232

September 28, 2005

• Recently Enacted Legislation Extends Return Filing, Tax Payment Deadlines for Victims of Hurricane Katrina

2005-231

September 28, 2005

• Legislative Update: Senate Committees Complete Pension Compromise

2005-230

September 28, 2005

• Treasury, IRS Provide Retroactive Guidance on the Effect of Certain Asset Reorganizations on Section 367(a) Gain Recognition Agreements

2005-229

September 28, 2005

• U.S. Supreme Court Agrees to Hear Ohio Investment Tax Credit Cases

2005-228

September 27, 2005

• Tax Court Rejects Tax-Free Reorganization; Instead Finds a $1.375 Billion Sale

2005-227

September 26, 2005

• IRS Issues Reminder of Withholding Tax Obligations for Certain U.S. Real Property Transactions Involving Foreign Persons

2005-226

September 26, 2005

• IRS Offers Tax Relief for Victims of Hurricane Rita

2005-225

September 26, 2005

• Court of Federal Claims: Informal Refund Claim Is Satisfied With Claims Filed on Original Tax Return Plus Taxpayer’s Conduct During the Audit

2005-224

September 23, 2005

• Estimated Tax Payments Sent to IRS’s San Francisco P.O. Box May Have Been Lost Due to Traffic Accident

2005-223

September 23, 2005

• Legislative Update: Katrina Tax Bill Sent to White House; JCT Releases Description of Katrina Bill

2005-222

September 22, 2005

• Aviation-Related Federal Excise Tax Provisions Are Modified, Effective September 30, 2005

2005-221

September 21, 2005

• IRS Summarizes Hurricane Katrina Tax Relief

2005-220

September 21, 2005

• Legislative Update: Congress Agrees on Katrina Tax Bill

2005-219

September 19, 2005

• Extension of Time Frames for Employee Benefit Plans Affected by Hurricane Katrina

2005-218

September 19, 2005

• United States, Mexico Reach Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities for Treaty Benefits

2005-217

September 16, 2005

• Proposed Regulations Address Source of Income from Certain Space and Ocean Activities, and Communication Activities

2005-216

September 16, 2005

• IRS Delays Effective Date of Schedule M-3 for Insurance Companies

2005-215

September 15, 2005

• Final Regulations Address the Point in Time for Measuring Whether the Section 368 “Continuity of Interest” Requirement is Satisfied

2005-214

September 15, 2005

• Guidance on Early Withdrawal of Retirement Assets for Disaster Victims, Relief from Dyed Diesel Fuel Penalty

2005-213

September 15, 2005

• Legislative Update: House, Senate on Separate Tracks for Hurricane Tax Relief

2005-212

September 14, 2005

• Guidance Concerning Whether a Pre-Spin-Off Merger and a Distribution are Part of a Section 355(e) “Plan”

2005-211

September 14, 2005

• IRS Launches Pilot Program for Expedited Corporate Private Letter Rulings

2005-210

September 14, 2005

• Legislative Update: Finance Leaders Introduce Katrina Bill

2005-209

September 13, 2005

• Guidance on How to Make a Stock Basis Reduction Election

2005-208

September 13, 2005

• Legislative Update: Finance Leaders Draft Katrina Relief Proposal

2005-207

September 12, 2005

• Guidance on Rules Relating to the Temporary Operation of Ships in Domestic Trade as a Result of Hurricane Katrina

2005-206

September 9, 2005

• Taxwriters Gear Up for Katrina-Related Bills; IRS Raises Mileage Rate

2005-205

September 9, 2005

• Hurricane Katrina: Deduction for Casualty Losses

2005-204

September 7, 2005

• Form W-2 Reporting for Qualified Dependent Assistance Using New Grace Period

2005-203

September 7, 2005

• IRS Web Page Lists Katrina-related Notices

2005-202

September 2, 2005

• IRS Suspends Penalty on Dyed Diesel Fuel Used on Highways

2005-201

September 2, 2005

• Federal Circuit: Taxpayer’s Affiliated Group Survived Downstream Merger

2005-200

September 2, 2005

• Eighth Circuit: Taxpayer Cannot Exclude Payment Under Termination Agreement as Personal Injury

2005-199

September 1, 2005

• Final Regulations on Estimated Tax by Individuals

2005-198

September 1, 2005

• IRS Announces Fourth-Quarter Interest Rates

Issue

Date

Subject

2005-197

August 30, 2005

• IRS Announces Special Relief for Taxpayers Affected by Hurricane Katrina

2005-196

August 26, 2005

• IRS Procedures for Rulings and Determination Letters for Certain Qualified Plans

2005-195

August 26, 2005

• Final Regulations Address Distributions of Life Insurance Contracts from Qualified Retirement Plans

2005-194

August 26, 2005

• IRS Releases Draft and Final Forms Related to Sections 199 and 965, and Draft Form for Electing Tonnage Tax Regime for International Shipping

2005-193

August 25, 2005

• IRS Guidance on Employer Subsidy for Medicare Prescription Drug Coverage

2005-192

August 25, 2005

• Proposed Changes to Update Existing FICA Regulations on Payments Made to Domestic Service Workers, Agricultural Laborers, and Other Home Workers

2005-191

August 25, 2005

• Proposed Regulations Address Employer Comparable Contributions to Health Savings Accounts

2005-190

August 25, 2005

• New Jersey: LANCO Decision Is Reversed—Intangible Licensor Established Nexus

2005-189

August 24, 2005

• Final Regulations Concerning the Determination of a U.S. Shareholder’s Pro Rata Share of Subpart F Income

2005-188

August 24, 2005

• Proposed Regulations Address Dividends Paid Deduction for Stock Held in ESOPs

2005-187

August 24, 2005

• Final Regulations Specify Time by Which Collectors of Federal Air Transportation and Communications Services Excise Taxes Must Report Taxpayers’ Refusals to Pay Tax

2005-186

August 19, 2005

• IRS Releases Third Installment of Repatriation Guidance Under Section 965

2005-185

August 19, 2005

• Temporary, Proposed Regulations Concerning Tax Consequences of Converting Non-Roth IRA Annuity to Roth IRA

2005-184

August 16, 2005

• Another Federal District Court Joins Ranks of Courts That Hold Certain Long-Distance Telephone Service Is Not Subject to Federal Communications Excise Tax

2005-183

August 16, 2005

• Waiver of 180-Day Period for Requesting Consent to Change a Method of Accounting Under Certain Regulations

2005-182

August 11, 2005

• Final and Proposed Regulatory Guidance on Elimination of Forms of Benefit From Qualified Retirement Plans

2005-181

August 10, 2005

• Energy Act Removes Exemptions for LUST Tax on Fuels

2005-180

August 10, 2005

• Federal Circuit: IRS Cannot Offset Erroneous Refund of Interest Against Later Arising Refunds of Tax and Interest for the Same Tax Year After the Statute of Limitations for Filing Suit to Recover Erroneous Refund Expired

2005-179

August 9, 2005

• Energy Policy Act of 2005: Changes to the Tax Law Affecting the Energy Sector

2005-178

August 8, 2005

• IRS Releases 2005-2006 Priority Guidance Plan

2005-177

August 5, 2005

• Treasury Delays Effective Date of International Shipping and Aircraft Regulations

2005-176

August 4, 2005

• Texas: Throwback Rule Held Unconstitutional

2005-175

August 3, 2005

• IRS Revises Criteria for Assessing Accountable Plan Rules Under Industry Issue Resolution Program Requests

2005-174

August 3, 2005

• IRS Guidance on Reimbursement Arrangements for Employee-Owned Tools

2005-173

August 2, 2005

• Treasury, IRS Revise and Update Rules for Accounting for Self-Constructed Assets

2005-172

August 2, 2005

• IRS Defines “Substantially Vested” With Respect to Certain Stock Options

2005-171

August 1, 2005

• IRS Issues Excise Tax Guidance Relating to Biodiesel and Aviation-Grade Kerosene

Issue

Date

Subject

2005-170

July 29, 2005

• Legislative Update: Senate Approves Energy Conference Report; Statutory Language of Highway Bill

2005-169

July 28, 2005

• Final Section 269B Regulations on “Stapled Stock”: Including Collecting Stapled Foreign Corporation’s U.S. Tax Liability From Stapled Domestic Corporation or From 10% Shareholders; Stapling Resulting in “F” Reorganization

2005-168

July 27, 2005

• IRS Guidance on Profit-Sharing Plans That Provide Medical Reimbursement Accounts

2005-167

July 27, 2005

• Legislative Update: House-Senate Conferees Near Agreement on Energy Conference Report

2005-166

July 26, 2005

• South Carolina: Overview of Recently Enacted Tax Legislation

2005-165

July 26, 2005

• Legislative Update: Senate Finance Approves Pension Changes

2005-164

July 22, 2005

• Legislative Update: Senate Panel to Consider Pension Bill

2005-163

July 21, 2005

• Legislative Update: Tax Technical Corrections Act of 2005 Is Introduced

2005-162

July 20, 2005

• Fifth Circuit: Value of Assets Transferred to Family Limited Partnership Properly Included in Taxable Estate

2005-161

July 19, 2005

• Louisiana: Recently Enacted Tax Legislation

2005-160

July 19, 2005

• Minnesota: Tax Legislation Includes New Criteria to Qualify for Foreign Operating Corporation Status, and Other Measures

2005-159

July 14, 2005

• Future Regulations to Change Determination of Foreign Bank’s Interest Expense Deduction Under Reg. Section 1.882-5

2005-158

July 13, 2005

• Proposed Regulations Provide Guidance on Electronic Employee Benefit Notices, Elections, and Consents

2005-157

July 13, 2005

• Final Regulations on Source of Compensation From Labor, Personal Services Performed Partly Within and Partly Outside the United States

2005-156

July 13, 2005

• Final Regulations for Apportioning Charitable Deductions Solely to U.S. Source Income; May Increase Foreign Tax Credit Limitation

2005-155

July 12, 2005

• IRS Changes Procedures to Allow Facsimile Signatures on Employment Tax Returns

2005-154

July 12, 2005

• IRS Guidance Concerning Appropriate Use of Summary Assessment Procedures When Individual Taxpayers Report Amount of Wages Differing from Amounts Shown on Forms W-2

2005-153

July 12, 2005

• Final Regulations for Making or Revoking a Section 179 Expensing Election on an Amended Tax Return

2005-152

July 11, 2005

• Final Regulations Concerning LIFO Recapture by C Corporations Converting to S Corporations

2005-151

July 8, 2005

• IRS Releases Guidance on Claiming Setoffs to Section 482 Adjustments

2005-150

July 8, 2005

• Ohio Enacts Sweeping Tax Reform Legislation

2005-149

July 5, 2005

• Grant Under State Program to Reimburse Disaster Losses is Not Excludable From Gross Income But May Be Deferred Under Like-Kind-Exchange Rules

2005-148

July 5, 2005

• Chicago Conference, July 21: Navigating the Section 965 Repatriation Provision

Issue

Date

Subject

2005-147

June 28, 2005

• Legislative Update: Senate Approves Energy Bill

2005-146

June 27, 2005

• Tax Court Notes Split Among Circuits in Addressing Deductibility of Investment Advisory Fees Incurred by a Trust

2005-145

June 27, 2005

• IRS Continues to Add to List of Vehicles Eligible for Clean-Burning Fuel Deduction

2005-144

June 23, 2005

• Reminder: Under Changes to Highway Use Tax Rules, Installment Payment Option Is No Longer Available

2005-143

June 23, 2005

• Drafts of the 2005 Version of Schedule M-3 and Instructions for Certain Corporate Tax Returns

2005-142

June 20, 2005

• IRS Establishes Requirements for Project to Be Designated as Qualified Green Building and Sustainable Design Project

2005-141

June 20, 2005

• IRS Addresses Treatment of Environmental Remediation Costs to Clean Up Land Contaminated by the Operation of Taxpayer’s Manufacturing Activities

2005-140

June 16, 2005

• Legislative Update: Deadline for Tax Reform Panel’s Report Extended to September 30th

2005-139

June 16, 2005

• IRS Guidance Concerning Golden Parachute Payments

2005-138

June 16, 2005

• Legislative Update: Senate Finance Committee Approves Tax Title to Energy Bill

2005-137

June 14, 2005

• Legislative Update: Senate Finance Prepares for Energy Bill Markup; Joint Committee Releases Descriptions of Highway Bill

2005-136

June 13, 2005

• Analysis: Treasury, IRS Guidance on Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004

2005-135

June 10, 2005

• Legislative Update: Boehner Pension Bill Would Address Cash Balance Plans

2005-134

June 9, 2005

• Legislative Update: House Leaders Propose Pension Bill

2005-133

June 7, 2005

• D.C. Circuit Affirms IRS’s Refusal to Disclose Contents of Closing Agreement

2005-132

June 3, 2005

• IRS Interim Guidance for Charitable Contributions of Motor Vehicles, Boats, and Airplanes

2005-131

June 3, 2005

• California Appellate Court Affirms Borders Decision, Finding Nexus on Sales by Online Bookseller

Issue

Date

Subject

2005-130

May 31, 2005

• IRS Releases Pre-Filing Agreement Report for 2004

2005-129

May 31, 2005

• Legislative Update: Joint Committee Releases ”Blue Book”

2005-128

May 27, 2005

• Guidance Issued on Expense Disallowance for Aircraft Provided for “Entertainment Flights” by “Specified Individuals”

2005-127

May 25, 2005

• Tax Court Finds Easement Donations Were Qualified Conservation Contributions Under Section 170

2005-126

May 25, 2005

• Proposed Restatement of the Section 415 Regulations on Limitations on Benefits and Contributions Under Qualified Plans

2005-125

May 23, 2005

• Final, Temporary Regulations on Assumption of Partner Liabilities

2005-124

May 23, 2005

• Proposed Regulations Concerning Application of Section 367 to Cross-Border Stock Transfers to Which Section 304 Applies

2005-123

May 20, 2005

• IRS Updates Procedure for Reopening Examinations

2005-122

May 20, 2005

• Temporary Research Credit Regulations Prescribe Method for Computing and Allocating a Credit for Members of a Controlled Group

2005-121

May 20, 2005

• Proposed Regulations Offer Safe Harbor for Valuation Under Section 475

2005-120

May 20, 2005

• Final Regulations Concerning the Deemed Election by Certain Eligible Entities to Be Taxable as Corporations

2005-119

May 20, 2005

• Proposed Regulations, Proposed Revenue Procedure on Equity Partnerships

2005-118

May 20, 2005

• Final Regulations on Mortgage Revenue Bonds Issued by State and Local Governments

2005-117

May 20, 2005

• IRS Guidance Concerning Charitable Contributions of Qualified Intellectual Property

2005-116

May 19, 2005

• Proposed Regulations Concerning Dual Consolidated Losses

2005-115

May 18, 2005

• IRS Guidance Allows Employees More Time to Spend FSA Funds

2005-114

May 18, 2005

• Final Regulations Replacing the Classification System for Determining Like-Class Properties for Section 1031 Purposes

2005-113

May 17, 2005

• Legislative Update: Senate Adopts Highway Bill

2005-112

May 16, 2005

• IRS Makes Available Draft Form for Section 965 Dividends Received Deduction

2005-111

May 13, 2005

• Final Section 1446 Regulations Addressing Withholding by Partnerships Engaged in a U.S. Trade or Business

2005-110

May 13, 2005

• Tenth Circuit: COLI Policy on Employee Violated Oklahoma Insurable Interest Doctrine

2005-109

May 11, 2005

• Automatic Six-Month Extension of Time Available for Issuing Authority Failing to Make Timely Carryforward Election of Unused Private Activity Bond Volume Cap

2005-108

May 11, 2005

• Eleventh Circuit: Long-Distance Telephone Service Not Subject to Federal Communications Excise Tax; District Court Is Reversed

2005-107

May 10, 2005

• Overview of Treasury, IRS Guidance on Section 965 Repatriations

2005-106

May 10, 2005

• Legislative Update: Senate to Consider Revenue Raisers on Highway Bill

2005-105

May 10, 2005

• IRS, Treasury Release Notice, Fact Sheet as Second Set of Repatriation Guidance Under Section 965

2005-104

May 9, 2005

• IRS Announces June 15th Closing Date for GUST Defined Contribution Pre-Approval Program

2005-103

May 6, 2005

• IRS Procedures on Change in Method of Valuation for Apportioning Interest Expenses for Foreign Tax Credit Purposes

2005-102

May 6, 2005

• IRS Updates List of Vehicles Eligible for Clean-Burning Fuel Deduction

2005-101

May 4, 2005

• Eighth Circuit: Truckstop Facilities Failed to Qualify as “Retail Motor Fuels Outlets” for 15-Year Depreciation

2005-100

May 4, 2005

• IRS Guidance for RIC Designated Dividend Distributions

Issue

Date

Subject

2005-99

April 29, 2005

• Legislative Update: House, Senate Approve Budget Resolution

2005-98

April 28, 2005

• Amounts Paid to Beneficiary Exceeding Decedent-Annuitant’s Investment in Annuity Found to Be Income in Respect of a Decedent

2005-97

April 26, 2005

• IRS, Professional Organizations Join Forces to Address Schedule M-3 Questions

2005-96

April 25, 2005

• Revenue Ruling Addresses Medicaid Rebates; IRS Indicates Current Treatment of Rebates Warrants Reconsideration

2005-95

April 19, 2005

• Legislative Update: Senate Finance Committee Markup of Highway Reauthorization, Excise Tax Simplification Bill; Would Require CEO’s Declaration on Corporate Income Tax Return

2005-94

April 18, 2005

• Description of Section 355(e) Final Regulations

2005-93

April 18, 2005

• IRS Addresses Retroactive Application of U.S. Supreme Court’s Decision for Certain Pension Plan Amendments

2005-92

April 18, 2005

• Section 355(e) Regulations Are Finalized

2005-91

April 14, 2005

• New York: Franchise Tax Nexus-Creating Activities of In-State Personnel

2005-90

April 13, 2005

• Legislative Update: Ways and Means Approves Energy Tax Provisions

2005-89

April 13, 2005

• Regulations Classify Societas Europaea and Certain Other Foreign Entities as “Per Se” Corporations

2005-88

April 13, 2005

• Sixth Circuit Affirms Trust Rate of Taxation Applies to VEBA’s Unrelated Business Taxable Income

2005-87

April 13, 2005

• Agreement Identifies UK Pension Arrangements for Tax Treaty Benefits

2005-86

April 13, 2005

• Regulations Amend Procedures Relating to Forms W-4

2005-85

April 13, 2005

• IRS Ruling Clarifies That HSA-Eligible Individuals Not Covered Under a Spouse’s Non-Eligible Health Plan May Make HSA Contributions

2005-84

April 11, 2005

• Legislative Update: Ways and Means Releases Energy Mark

2005-83

April 8, 2005

• Safe Harbor Guidance on Fair Market Valuation of Life Insurance Contracts

2005-82

April 6, 2005

• Temporary, Proposed Regulations Provide Guidance for Taxpayers in U.S. Possessions

2005-81

April 6, 2005

• Louisiana Supreme Court Finds Jurisdiction Over Dividend Income That Nonresident Owner Received From a REIT; Possible Implications for Nonresident Owners of Other Entities?

2005-80

April 4, 2005

• Court of Federal Claims Once Again Finds for Taxpayer in Federal Communications Excise Tax Refund Action

2005-79

April 4, 2005

• Court of Federal Claims Finds Taxpayer Is Entitled to Foreign Tax Credit—Luxembourg Parent Solely Liable for Luxembourg Tax of Luxembourg Consolidated Group

2005-78

April 1, 2005

• Interim Procedures for Partnerships to Comply with Mandatory Basis Provisions of Sections 734 and 743, and for Electing Investment Partnerships

Issue

Date

Subject

2005-77

March 30, 2005

• IRS Provides Safe Harbor for Charitable Remainder Annuity Trusts Regarding State-Law Elections of Surviving Spouses

2005-76

March 29, 2005

• Proposed Regulations Would Reinstate Relief for Withholding on Certain Payments Made to Foreign Persons

2005-75

March 24, 2005

• Kentucky Enacts Sweeping Tax Reform Legislation

2005-74

March 22, 2005

• IRS Announces Luxury Automobile Depreciation Deduction Limitations for 2005

2005-73

March 21, 2005

• Final Regulations Concerning Treatment of Installment Obligations, Contributed Contracts Under Sections 704(c) and 737

2005-72

March 21, 2005

• Final Regulations for Consolidated Groups When Group Member Realizes Discharge of Indebtedness Income

2005-71

March 18, 2005

• Legislative Update: House, Senate Pass Different Budget Plans

2005-70

March 18, 2005

• Legislative Update: Tax Committee Leaders Write Treasury on Guidance, Pending Technical Corrections

2005-69

March 17, 2005

• IRS Revenue Ruling Addresses AMT Deduction for Home Mortgage Interest on Refinanced Mortgages

2005-68

March 17, 2005

• Treasury, IRS Request Comments, Recommendations for Items to Include in 2005-2006 Guidance Priority List

2005-67

March 17, 2005

• Final Regulations on Election to Treat Qualified Dividend Income as Investment Income

2005-66

March 15, 2005

• Tax Court: Transfers Did Not Satisfy Bona Fide Sale in Context of Family Limited Partnership

2005-65

March 15, 2005

• IRS Guidance Concerning Truck Bodies Subject to Federal Excise Tax

2005-64

March 15, 2005

• Final Regulations Provide Ordering Rules for Charitable Remainder Trusts

2005-63

March 14, 2005

• Legislative Update: Congress Takes Up Competing Budget Blueprints

2005-62

March 14, 2005

• IRS Procedures Concerning Deposits to Suspend the Running of Interest on Tax Underpayments

2005-61

March 11, 2005

• IRS Guidance on Election to Deduct State and Local General Sales Taxes

2005-60

March 10, 2005

• Discussion: IRS Transition Relief for 2004 Tax Years From Loss Disallowance Rules for Property Owned by a Partnership with a Tax-Exempt Partner

2005-59

March 10, 2005

• Proposed Regulations Address FICA Treatment of Workers’ Compensation Payments

2005-58

March 10, 2005

• IRS Provides Transition Relief to Partnerships and Pass-Thru Entities Under New Code Section 470

2005-57

March 9, 2005

• Proposed Regulations on Reorganizations Involving an Insolvent Corporation

2005-56

March 8, 2005

• Treasury, IRS Intend to Modify Regulations Concerning Exchange Rate Used for Determining Gain/Loss on Transfer of Assets From Qualified Business Unit to U.S. Home Office

2005-55

March 8, 2005

• IRS Guidance Modifies Accounting Method Change Procedures Relating to Capitalization of Intangible Assets

2005-54

March 8, 2005

• Legislative Update: Senate Defeats Tax Amendment to Bankruptcy Bill

2005-53

March 7, 2005

• IRS Requests Issues for Industry Issue Resolution Program by March 31, 2005

2005-52

March 7, 2005

• U.S. Supreme Court: Tax Court Cannot Conceal Reports of Special Trial Judges

2005-51

March 4, 2005

• Legislative Update: Senate to Consider Tax Amendment to Bankruptcy Bill

2005-50

March 3, 2005

• Proposed Regulations Concerning Collection of Tax Liabilities After Assessment

2005-49

March 2, 2005

• Treasury Updates Facts Sheets on Tax Policy

2005-48

March 2, 2005

• Loss Limitation Rules: Final Regulations Are Released

2005-47

March 1, 2005

• Regulations Establish Period for Filing Amended Returns Concerning John Doe Summonses, Listed Transactions

2005-46

March 1, 2005

• Proposed Regulations Released on Roth 401(k) Contributions

Issue

Date

Subject

2005-45

February 24, 2005

• Final Regulations Concerning COI and COBE for "E" and "F" Reorganizations

2005-44

February 24, 2005

• Final Regulations Concerning Dispute Procedures Regarding the Ownership of Residual Interests in a REMIC

2005-43

February 24, 2005

• Final Regulations Clarify Modification of Check the Box Rules

2005-42

February 23, 2005

• Tax Reform Panel Announces Public Meetings Schedule for March 2005

2005-41

February 23, 2005

• IRS Redesigns Form 941, Employer’s Quarterly Federal Tax Return, and Instructions; Signature No Longer Required on Form 7004, Application for Automatic Extension of Time to File Corporate Income Tax Return

2005-40

February 22, 2005

• Final Regulations Provide Adjustments for S Corporations Concerning Net Unrealized Built-in Gain for Certain Assets Acquired From C Corporations

2005-39

February 22, 2005

• Final Regulations on Uniform Capitalization of Interest Expense in Safe Harbor Sale and Leaseback Transactions

2005-38

February 18, 2005

• Court of Federal Claims Joins Ranks of Federal District Courts, Finding for Taxpayer in Federal Communications Excise Tax Refund Action

2005-37

February 18, 2005

• Proposed Regulations Address Treatment of Intercompany Gains on Liquidation of Consolidated Group Member

2005-36

February 18, 2005

• Sixth Circuit Affirms Off-Wing Service of Airplane Engines and Auxiliary Power Units as Ordinary and Necessary Expense

2005-35

February 18, 2005

• Legislative Update: Tax Reform Panel Requests Public Comment

2005-34

February 18, 2005

• White House Issues Economic Report, Includes Discussions of Tax Reform Options

2005-33

February 17, 2005

• FASB Discusses Standard for Uncertain Tax Positions

2005-32

February 17, 2005

• IRS Guidance Related to Section 936 and Section 30A Credit Terminations

2005-31

February 16, 2005

• Legislative Update: Tax Reform Panel Holds First Hearing

2005-30

February 16, 2005

• Michigan: SBT Treatment of Single Member LLCs and Corporate Members Using Different Tax Bases Is Clarified; Proposals for SBT Relief Are Unveiled

2005-29

February 14, 2005

• Legislative Update: Grassley Seeking Offsets for Tax Cut Extensions

2005-28

February 10, 2005

• United States, New Zealand Reach Mutual Agreement Concerning Treatment of Income Derived Through Certain Fiscally Transparent Entities

2005-27

February 10, 2005

• IRS Guidance for Determining NOL Eligibility Under the 10-Year Carryback Rule for Specified Liability Loss

2005-26

February 9, 2005

• Tax Court: Gain Cannot Be Deferred in Like-Kind Exchanges Between Related Parties

2005-25

February 7, 2005

• Legislative Update: Observations on President’s Proposed $1.4 Trillion in Net Tax Cuts

2005-24

February 7, 2005

• Legislative Update: Bush Administration’s Fiscal Year 2006 Budget Is Released

2005-23

February 3, 2005

• 2004 Act Provision Disallowing Deductions on Property Used by a Tax-Exempt Entity Has a Potentially Long Reach to Property Owned by a Partnership With a Tax-Exempt Entity as a Partner

Issue

Date

Subject

2005-22

January 31, 2005

• Tax Court: Lease Strip Transactions Lacked Economic Substance

2005-21

January 31, 2005

• Legislative Update: President’s Tax Reform Advisory Panel Schedules First Public Meeting for February 16

2005-20

January 27, 2005

• IRS Guidance on Like-Kind Exchange of a Taxpayer’s Principal Residence

2005-19

January 27, 2005

• Legislative Update: Joint Committee Releases Report on Options for Improving Tax Compliance, Reforming Tax Expenditures

2005-18

January 24, 2005

• Final Regulations Provide Guidance on Elimination of Forms of Benefit from Defined Contribution Plans

2005-17

January 21, 2005

• Ohio: Petition for Rehearing Denied by Sixth Circuit in Cuno v. DaimlerChrysler

2005-16

January 19, 2005

• IRS Revokes Assets-Over Partnership Merger Guidance, Announces Intent for Regulations to Address Income Tax Consequences of Property Distributions After Partnership Mergers

2005-15

January 19, 2005

• Treasury, IRS Release Interim Guidance for Calculating the Deduction for Domestic Production Activities

2005-14

January 19, 2005

• IRS Guidance Concerning New Penalties on Potentially Abusive Transactions

2005-13

January 13, 2005

• Discussion of Treasury, IRS Guidance on Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004

2005-12

January 13, 2005

• Treasury, IRS Guidance on Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004

2005-11

January 13, 2005

• Additional Tax Relief for Like-Kind Exchanges for Taxpayers Affected by Certain Natural Disasters and Terrorist, Military or Other Actions

2005-10

January 12, 2005

• IRS Notice Addresses Partnership Contributions to Partners’ Health Savings Accounts

2005-09

January 7, 2005

• White House Announces Members of President's Advisory Panel on Federal Tax Reform

2005-08

January 7, 2005

• Certain IRS User Fees for Ruling Requests to Increase After February 28, 2005

2005-07

January 6, 2005

• Legislative Update: Congress Approves Bill Allowing Extended Charitable Deduction for Tsunami Relief

2005-06

January 6, 2005

• U.S. Federal Tax Implications of Assistance Provided to Tsunami Victims

2005-05

January 5, 2005

• IRS Clarifies Transition Rules Under Deferred Compensation Guidance

2005-04

January 5, 2005

• Final Regulations Under Section 367(a) to Be Amended Concerning Certain Exchanges of Securities for Stock or Securities

2005-03

January 5, 2005

• Stricter Penalty Provisions for Late-Filed Information Reports of Foreign Bank Accounts

2005-02

January 4, 2005

• Regulations Released on Withholding for Supplemental Wages

2005-01

January 4, 2005

• IRS Publishes Proposed Regulations Relating to Statutory Mergers or Consolidations and Other Reorganizations Involving a Foreign Corporation

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