INCOME TAX

Rev. Rul. 2005–25, page 971. Health Savings Accounts (HSAs); non-high deductible health plan (HDHP). This ruling provides guidance on eligibility and contribution rules under section 223 of the Code for a married individual whose spouse has non-high deductible health plan (HDHP) coverage. A married individual may contribute to a Health Savings Account (HSA) even though his or her spouse has non-HDHP coverage, so long as the individual is not covered by the spouse’s non-HDHP. The maximum amount that an eligible individual may contribute to an HSA is based on whether the individual has self-only or family HDHP coverage.

T.D. 9197, page 985. REG–148521–04, page 995. Final, temporary, and proposed regulations under section 7701 of the Code add to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification. A public hearing on the proposed regulations is scheduled for July 27, 2005.

T.D. 9198, page 972. Final regulations under section 355(e) of the Code relate to the recognition of gain on certain distributions of stock or securities in connection with an acquisition. The regulations provide guidance on whether an acquisition and a distribution are part of a plan (or series of related transactions).

Rev. Proc. 2005–20, page 990. This procedure describes how a regulated investment company (RIC) that holds a partnership interest is treated. A RIC that is a consenting partner in a partnership, that has in effect a monthly

Finding Lists begin on page ii.