INCOME TAX

T.D. 9243, page 475. Final and temporary regulations under section 367 of the Code amend income tax regulations under sections 367, 884, and 6038B dealing with statutory mergers or consolidations under section 368(a)(1)(A) involving one or more foreign corporations, and provide guidance necessary to facilitate business electronic filing under section 6038B.

T.D. 9244, page 463. REG–138879–05, page 503. Final regulations under section 358 of the Code provide a tracing approach for the determination of basis of stock or securities received in exchange for or with respect to stock and securities in certain transactions. Temporary and proposed regulations under section 1502 of the Code provide additional guidance on the treatment of an excess loss account when a consolidated group member’s original shares have an excess loss account or the member would otherwise determine that new shares would have an excess loss account at the time of a basis adjustment or determination under the Internal Revenue Code. Rev. Rul. 55–355 obsoleted.

Notice 2006–13, page 496. This notice announces that the IRS and Treasury intend to issue final regulations under section 1503(d) of the Code to provide that a reasonable cause standard similar to proposed regulations section 1.1503(d)–1(c)(1) will apply to cure all late filings under section 1503(d). Prior to issuance of those regulations, taxpayers may rely on the reasonable cause procedure set forth in proposed regulations section 1.1503(d)–1(c)(1), as modified by this notice, to cure late filings under the current regulations. Additionally, until the final regulations are issued, taxpayers may choose to apply for relief for untimely sec

Finding Lists begin on page ii.