Internal Revenue Bulletins  
March 28, 2005

Internal Revenue Bulletin No. 2005-13

Links to Official IRS Bulletin Documents listed below are in the Adobe Acrobat PDF Format, and require the appropriate Acrobat Reader to view and/or print.

INCOME TAX

Notice 2005-27(PDF, 92K)
This notice discusses the proper exchange rate to be used under the dollar approximate separate transactions method (DASTM) of regulations section 1.985-3(d) to translate certain types of assets transferred from a qualified business unit to its U.S. home office.

Notice 2005-28(PDF, 88K)
This notice extends the deadline by which state and local governments must nominate projects for designation by the Secretary as qualified green building and sustainable design projects under section 142(l) of the Code.

Notice 2005-29(PDF, 92K)
Transition relief for certain partnerships and other passthru entities under section 470. This notice provides transition relief under section 470 of the Code to partnerships and other pass-thru entities that are treated as holding tax-exempt use property because of the application of section 168(h)(6).

T.D. 9186(PDF, 124K)
REG-122847-04(PDF, 95K)
Temporary and proposed regulations under section 6664 of the Code provide additional circumstances that end the period within which a taxpayer may file an amended return that constitutes a qualified amended return. The regulations provide that the period for filing a qualified amended return is terminated once the IRS has served a John Doe summons on a third party with respect to the taxpayer�s tax liability. In addition, for taxpayers who have claimed tax benefits from undisclosed listed transactions, the regulations provide that the period for filing a qualified amended return is terminated once the IRS contacts a promoter, organizer, seller, or material advisor concerning the listed transaction. The regulations also provide that the date on which published guidance is issued announcing a settlement initiative for a listed transaction in which penalties are compromised or waived is an additional date by which a taxpayer must file a qualified amended return. Notice 2004-38 obsoleted.

REG-148701-03(PDF, 104K)
Proposed regulations under section 6502 of the Code incorporate the changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS�s ability to enter into agreements extending the statute of limitations for collection. The regulations also incorporate a provision governing the continued effect of collection statute extension agreements executed prior to January 1, 2000.

Rev. Rul. 2005-16(PDF, 90K)
Low-income housing credit; satisfactory bond; "bond factor" amounts for the period January through June 2005. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through June 2005.

Rev. Rul. 2005-22(PDF, 93K)
LIFO; price indexes; department stores. The January 2005 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, January 31, 2005.

T.D. 9187(PDF, 194K)
Final regulations under sections 337(d) and 1502 of the Code disallow certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns and to purchasers of stock of members of a consolidated group.

EMPLOYEE PLANS

REG-152354-04(PDF, 107K)
Proposed regulations under section 401(k) of the Code would provide guidance concerning the requirements for designated Roth contributions to qualified cash or deferred arrangements. The regulations would affect section 401(k) plans that provide for designated Roth contributions and participants eligible to make elective contributions under these plans.

ADMINISTRATIVE

Notice 2005-28(PDF, 88K)
This notice extends the deadline by which state and local governments must nominate projects for designation by the Secretary as qualified green building and sustainable design projects under section 142(l) of the Code.

REG-148701-03(PDF, 104K)
Proposed regulations under section 6502 of the Code incorporate the changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS�s ability to enter into agreements extending the statute of limitations for collection. The regulations also incorporate a provision governing the continued effect of collection statute extension agreements executed prior to January 1, 2000.

Rev. Proc. 2005-17(PDF, 82K)
This procedure modifies Rev. Proc. 2005-9 to waive the 5-year prior change scope limitation for taxpayers seeking the Commissioner�s automatic consent to change a method of accounting for the costs of acquiring or creating intangibles. Rev. Proc. 2005-9 modified.

Rev. Proc. 2005-18(PDF, 95K)
This document provides procedures for making, withdrawing, or otherwise identifying deposits under new section 6603 of the Code to suspend the running of interest under section 6601 on potential underpayments of tax. Section 6603 was added to the Code by the American Jobs Creation Act of 2004. The procedure also invites comments from the public regarding rules and standards relating to new section 6603. Rev. Proc. 84-58 superseded.

T.D. 9189(PDF, 99K)
Final regulations under section 6334 of the Code revise regulations relating to property exempt from levy. The regulations were revised to reflect changes made by the IRS Restructuring and Reform Act of 1998 and the Taxpayer Relief Act of 1997. These changes include the procedures for obtaining prior judicial approval of certain principal residence seizures and the exemption from levy for certain business assets in the absence of administrative approval or jeopardy.

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