Internal Revenue Bulletin: 2005-11 |
March 14, 2005 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
- Part III. Administrative, Procedural, and Miscellaneous
- Notice 2005-21
- BACKGROUND
- SECTION I. THE SECTION 936 CORPORATION CONTINUES ITS ACTIVITIES AS A DOMESTIC CORPORATION.
- SECTION II. THE SECTION 936 CORPORATION LIQUIDATES INTO ITS DOMESTIC PARENT CORPORATION.
- SECTION III. THE SECTION 936 CORPORATION REINCORPORATES
AS A FOREIGN CORPORATION.
- A. Section 367 consequences of a section 368(a)(1)(F) reorganization
- B. Effect of termination of section 936 on the use and transfer of intangibles
- C. Subsequent dividends from earnings accumulated by the section 936 corporation
- D. Alternative minimum tax
- E. Recapture of dual consolidated losses
- F. Reporting requirements
- G. Subpart F consequences to U.S. shareholders
- DRAFTING INFORMATION
- Notice 2005-23
- Notice 2005-21
- Part IV. Items of General Interest
- REG-131128-04
- Announcement 2005-15
- Consent Disbarments From Practice Before the Internal Revenue Service
- Suspensions From Practice Before the Internal Revenue Service After Notice and an Opportunity for a Proceeding
- Consent Suspensions From Practice Before the Internal Revenue Service
- Expedited Suspensions From Practice Before the Internal Revenue Service
- Censure Issued by Consent
- Announcement 2005-19
- Section 1. Purpose of the Initiative
- Section 2. The Parties and Eligibility Requirements
- Section 3. Settlement Terms for Participating Parties
- Section 4. Procedures for Closing Cases
- Section 5. Non-Participants’ Dispute Resolution Procedures
- Section 6. Paperwork Reduction Act
- Section 7. Contact Information
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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