Bulletin No. 2005-24 June 13, 2005

harbor and may require certain adjustments to values used in the safe harbor. This safe harbor attempts to reduce the compliance burden upon taxpayers and to improve the administrability of valuations for the IRS. A public hearing is scheduled for September 15, 2005.

REG–105346–03, page 1244. Proposed regulations under section 83 of the Code withdraw the remaining portion of the notice of proposed rulemaking published in the Federal Register on June 3, 1971 (36 FR 10787) and contain proposed regulations relating to the tax treatment of certain transfers of partnership equity in connection with the performance of services. The regulations provide that the transfer of a partnership interest in connection with the performance of services is subject to section 83 and provide rules for coordinating section 83 with partnership taxation principles. The regulations also provide that no gain or loss is recognized by a partnership on the transfer or vesting of an interest in the transferring partnership in connection with the performance of services for the transferring partnership. A public hearing is scheduled for October 5, 2005.

REG–127740–04, page 1254. Proposed regulations under sections 367(a) and (b) of the Code relate to certain transfers of stock involving foreign corporations pursuant to section 304(a)(1).

Notice 2005–43, page 1221. This notice includes a proposed revenue procedure providing additional rules for the elective safe harbor under the proposed regulations under section 83 of the Code governing the application of section 83 to the transfer of a partnership interest in connection with the performance of services.

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Notice 2005–45, page 1228. Deductions for entertainment use of aircraft. This notice provides interim guidance to taxpayers on the limitation under section 274(e) of the Code on the deductible amount of trade or business expenses incurred after October 22, 2004, for use of a business aircraft for entertainment.