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

Rev. Rul. 2005–15, page 720. Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning April 1, 2005, will be 6 percent for overpayments (5 percent in the case of a corporation), 6 percent for underpayments, and 8 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 3.5 percent.

T.D. 9179, page 707. Final regulations under section 263A of the Code except interest expense incurred by a lessor in certain safe harbor leasing transactions from the requirement to capitalize interest.

T.D. 9180, page 714. Final regulations under section 1374 of the Code provide for an adjustment to the amount that may be subject to tax under section 1374 in certain cases in which an S corporation acquires assets from a C corporation in an acquisition to which section 1374(d)(8) applies. The regulations provide guidance to certain S corporations that acquire assets from a C corporation in a carryover basis transaction.

T.D. 9182, page 713. Final regulations under section 368 of the Code provide that a continuity of the business enterprise and a continuity of interest are not required for the transaction to qualify as a reorganization under section 368(a)(1)(E) or (F). Rev. Ruls. 69–516, 77–415, 77–479, and 82–34 obsoleted.

Announcements of Disbarments and Suspensions begin on page 738. Finding Lists begin on page ii.