Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis. The commentator also expressed concern about the interaction of the proposed regulation with §1.864-5(a), which provides, generally, that foreign source income, such as a foreign-source dividend or gain, cannot constitute U. effectively connected income in circumstances in which a U. The IRS invited comments whether the 10 percent threshold provided in the proposed regulation was an appropriate standard for determining whether stock is a portfolio investment.It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. The commentator stated that it was possible for insurance companies to make a strategic investment in a corporation at a level below 10 percent of the vote or value of the corporation, such as by purchasing a special class of shares that conveyed the power to elect directors.The regulations affect taxpayers against whose property or rights to property the Service files an NFTL. This document contains final regulations relating to the determination of income of foreign insurance companies that is effectively connected with the conduct of a trade or business within the United States.A public hearing is scheduled for January 19, 2006. The regulations provide that the exception to the asset-use test for stock shall not apply in determining whether the income, gain, or loss from portfolio stock held by foreign insurance companies constitutes effectively connected income. No requests for a public hearing were received, and no public hearing was held.
A public hearing is scheduled for January 25, 2006. The principal author of this revenue ruling is David Mc Donnell of the Office of Associate Chief Counsel (Passthroughs and Special Industries).
Proposed regulations under section 6330 of the Code relate to a taxpayer’s right to a hearing before or after levy. The IRS received one written comment in response to the notice of proposed rulemaking.
The regulations make certain clarifying changes in the way collection due process hearings are conducted and specify the period during which a taxpayer may request an equivalent hearing. After consideration of the comment, the proposed regulation is adopted without change.
The regulations affect taxpayers against whose property or rights to property the Service proposes to levy. This Treasury decision adopts the language of the proposed regulation without change.
A public hearing is scheduled for January 19, 2006. The IRS received one comment in response to the proposed regulation.