Bulletin No. 2005-25 — Internal Revenue Bulletin 2005-25

T.D. 9206, page 1283. REG–158138–04, page 1341. Temporary and proposed regulations under section 6050L provide guidance for the filing of information returns by donees relating to qualified intellectual property contributions. The regulations affect donees receiving net income from qualified intellectual property contributions after June 3, 2004.

REG–168892–03, page 1293. Proposed regulations under section 7702 of the Code define the attained age of the insured under contracts intending to qualify as life insurance contracts and explain how to use that age to test whether a contract qualifies as a life insurance contract for federal income tax purposes. A public hearing is scheduled for September 14, 2005.

REG–102144–04, page 1297. Proposed regulations under section 1503(d) of the Code address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, such loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. A public hearing is scheduled for September 7, 2005.

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Notice 2005–44, page 1287. Charitable contributions of qualified vehicles. This notice provides interim guidance under section 170(f)(12) of the Code regarding the deductibility of vehicle contributions. The notice explains the new requirements applicable to the acknowledgments that donee organizations provide to vehicle donors. In addition, the notice provides guidance on the new penalties section 6720 imposes on donee organizations that provide a false or fraudulent acknowledgment of a vehicle contribution, or fail to properly furnish the acknowledgment. Sections 170(f)(12) and 6720 are effective for vehicle contributions made after December 31, 2004.